41st Parameter Privacy Policy

Introduction
41st Parameter provides fraud prevention services and application hosting on behalf of our clients. As a hosting provider, we receive a variety of data from our clients in regards to online transactions. We respect consumers’ online privacy and are committed to following industry privacy standards and directives. This privacy policy describes the nature of how this data is stored and secured while at 41st Parameter. Consumers should also review the privacy policy of their direct merchant or financial provider in addition to this policy.

Compliance with U.S – EU Safe Harbor Principles
As a ‘processor’ of data on behalf of e-commerce merchants, travel providers, and financial institutions we do not get data directly from the consumer, but we are committed to complying with the principles of Safe Harbor as it applies to processors. 41st Parameter adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to such data. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, and how we use it.

We self-certify compliance with

Purpose of Data Received
In the course of providing fraud prevention and application hosting services on behalf of our clients, 41st Parameter may receive consumer data that would be relevant in our clients online processing. This data may include, but not be limited to, items such as consumer name, billing address, email address, and payment instrument (“Personal Information”). This data is used for analysis to prevent online financial fraud and only retained for a limited amount of time.

41st Parameter never discloses client data or consumer personal information outside of our company or business partners without knowledge and consent, except when obligated by law.

Notice
41st Parameter informs individuals of the purpose for which it collects and uses the Personal Information and the uses of the data via our privacy policy on this website. 41st Parameter also works with its clients to identify the types, format, and security of the data sent to 41st Parameter.

Choice
41st Parameter receives data directly from our clients; never is data received directly from an individual. In doing so, 41st Parameter clients with direct contact with the consumer would be encouraged to provide the necessary notice and opt-in choices on Personal Information. Again, it is important to note that 41st Parameter never discloses client data or consumer personal information outside of our company or business partners without knowledge and consent, except when obligated by law.

Onward Transfers
41st Parameter will not transfer data it receives to any outside party. If in any event this became a requirement, 41st Parameter would notify the client and the consumer prior to disclosing Personal Information to a third party. 41st Parameter would also ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.

Data Security
41st Parameter takes reasonable steps to protect the Personal Information it stores and has put in place appropriate physical, electronic and managerial procedures to safeguard and secure it from loss, misuse, unauthorized access or disclosure, alteration or destruction. We cannot guarantee the security of Personal Information on or transmitted via the Internet.

Data Integrity
41st Parameter only processes Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by our client. To the extent necessary for those purposes, we take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access
41st Parameter will allow an individual access to their Personal Information to the extent it is available and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Enforcement
41st Parameter uses a self-assessment approach to assure compliance with this 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. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using BBB EU Safe Harbor as a third party resolution provider.

Amendments
This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website.

41st Parameter is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of 41st Parameter that may differ in some respects from the general policies set forth in this privacy policy.

Contact Information
Questions, comments or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:

41st Parameter
Attn: Security Officer
17851 N. 85th Street #250
Scottsdale, AZ 85255 USA
Effective date: January 1, 2010

Privacy Complaints by European Union Citizens:
In compliance with the Safe Harbor Principles, 41st Parameter commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact 41st Parameter at:

41st Parameter
Attn: Security Officer
17851 N. 85th Street #250
Scottsdale, AZ 85255
Security@the41.com

41st Parameter has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by the Security Officer at 41st Parameter you may contact:

Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Phone: 703-276-0100
Web: www.us.bbb.org
Email: eusafeharbor@council.bbb.org