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Safe Harbor Policy

(Updated October 14, 2014)
INTRODUCTION

FORTESSA TABLEWARE SOLUTIONS, LLC, a Virginia limited liability company (“FTS”)."FTS") is committed to safeguarding the private information entrusted to it by customers, which is why FTS adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") to the United States. FTS complies with the U.S.-EU Safe Harbor Framework and follows the Safe Harbor Privacy Principles published by the U.S. Department of Commerce (the "Principles") with respect to all private data.

SCOPE

This Safe Harbor Privacy Policy (the "Policy") outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by FTS whether in electronic, paper or verbal format.

If there is any conflict between the policies in this Policy and the Principles, the Principles shall govern. This Policy is intended to supplement the FTS Privacy Policy, which can be found at INSERT. To learn more about the Safe Harbor Framework, please visit http://export.gov/safeharbor/.

DEFINITIONS
  • 1. "Agent" means any third party that processes, collects, or uses Personal Information under the instructions of, and solely for, FTS or to which FTS discloses Personal Information for use on FTS's behalf.
  • 2. "EU" has the meaning attributed to it in the first unnumbered paragraph.
  • 3. "FTS" has the meaning attributed to it in the first unnumbered paragraph.
  • 4. "Personal Information" or "Information" means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, specific individual; and (4) can be linked to that individual.
  • 5. "Policy" has the meaning attributed to it in the second unnumbered paragraph.
  • 6. "Principles" has the meaning attributed to it in the first unnumbered paragraph.
  • 7. "Sensitive Personal Information" means Personal Information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual's health.
PRINCIPLES
  • 1. NOTICE.
    Fortessa Tableware Solutions, LLC shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-Agent third parties to which FTS discloses or may disclose that Information. FTS shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to FTS, or as soon as practicable thereafter, and in any event before FTS uses or discloses the Information for a purpose other than for which it was originally collected.
  • 2. CHOICE
    Fortessa Tableware Solutions, LLC will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a non-Agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, FTS will give individuals the opportunity to affirmatively or explicitly (opt in) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
  • 3. DISCLOSURES AND ONWARD TRANSFERS

    Prior to disclosing Personal Information to a third party, FTS shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. FTS may disclose Private Information to its Agents in order for those Agents to obtain information needed to perform their functions. However, FTS's Agents are restricted from using the Personal Information for purposes other than providing services for or to FTS. FTS requires that its Agents that have access to Personal Information either subscribe to the Principles, are subject to a law providing an adequate level of privacy protection, or agree in writing to provide an adequate level of privacy protection.

    Fortessa Tableware Solutions, LLC also may disclose Personal Information as required by law, legal process, or mandatory professional standards. Before making any such disclosure, to the extent practical, FTS will take reasonable steps to inform the customer of the intended disclosure so that the individual may take such actions as it deems necessary to protect the Personal Information.

  • 4. DATA SECURITY

    Fortessa Tableware Solutions, LLC will take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. FTS has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. FTS cannot guarantee the security of Information on or transmitted via the Internet.

  • 5. DATA INTEGRITY

    Fortessa Tableware Solutions, LLC shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, FTS shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

  • 6. ACCESS

    Upon request, to the extent practical, FTS will provide individuals with reasonable access to their Personal Information. FTS will take reasonable steps to permit these individuals to correct, amend or delete any Personal Information that is demonstrated to be inaccurate or incomplete. FTS may limit or deny access to Personal Information as permitted by the Principles. For example, FTS may limit an individual's access to Personal Information where the burden or expense of providing access would be disproportionateto the risks to the individual's privacy or where the legitimate rights of persons other than the individual would be violated.

  • 7. ENFORCEMENT

    Fortessa Tableware Solutions, LLC uses a self-assessment approach to assure compliance with this Safe Harbor Privacy Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. FTS encourages interested persons to raise any concerns using the contact information provided below. FTS will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

    Information in accordance with the Principles. If a complaint or dispute cannot be resolved through FTS's internal process, FTS and the individual agree to dispute resolution using the American Arbitration Association as a third party resolution provider.

AMENDMENTS

This Policy may be amended from time to time consistent with the requirements of the Safe Harbor Framework and Principles. Any such revised Policy will become effective as of the date it is posted on FTS's website.

CONTACT INFORMATION

Questions, comments or complaints regarding FTS's data collection and processing practices can be directed to:

FORTESSA TABLEWARE SOLUTIONS, LLC ATTN: Martin G. Hamberger, Executive Vice President 22601 Davis Drive Sterling, Virginia 20164 info@fortessa.com 800-296-7508