1. INFORMATION COLLECTED
Non-personal information is information that cannot be used to directly or indirectly identify a person. POS Corp automatically collects and stores non-personally identifiable information about you to POS Corp’s Web sites by tracking the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browsing software you use and your operating systems; the date and time you access our Web sites; and the Internet address of the site from which you linked directly to our Web sites. We use this information only as anonymous aggregate data to determine the number of visitors to different sections of our Web sites, to ensure our Web sites are working properly, and to help us make our Web sites more useful. POS Corp does not collect any other non-personally identifiable information.
Personal information is information that can be used to directly or indirectly identify a person. Some examples of personal information are: name, home or email address, home telephone number, identification number (e.g. social security number or social insurance number), financial information and physical characteristics.
POS Corp may collect personal information from you through POS Corp’s Web sites to respond to information requests from you about POS Corp’s products and services, and for investor relations material. For example, customers that contact us are asked for their name, address, telephone number, store name/concept, number of stores and email address. Investors are asked for name, company, address, telephone number, email address and what type of investor relations material they are requesting. POS Corp also collects personal information from customers and business partners for general business purposes (specifically, reviewing customer credit and/or financial history, entering into contracts for products and services, processing orders and payments for products and services and providing support services to customer, all at customer’s request.
2. USE OF INFORMATION
POS Corp will only use the information you provide to us for:
the purpose for which such information was provided;
delivery of information to you about our company, our products and other promotional materials; and
offering you, through a third party, who we may provide with your contact information, products and services related to the products and services that you purchase from POS Corp.
If you do not want POS Corp to provide your contact information to a third party in order to offer you products and services related to the products and services that you purchase from POS Corp, you can choose to opt-out by contacting POS Corp’s Privacy Officer as instructed in Section 10 below.
Some of POS Corp’s Web sites use security measures, such as encryption, to protect the information that we collect from you. We will however take all reasonable steps to insure the safety of any personal information collected from you through POS Corp’s Web sites that do not use encryption.
Storage, Retention, and Accuracy of Personal Information
POS Corp takes reasonable precautions to protect personal information from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Personal information is maintained in secure electronic and manual files at POS Corp, and access to these files is limited to POS Corp employees for whom access is necessary to properly process the personal information consistent with the stated purposes.
POS Corp will retain your personal information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. Your consent to such purpose(s) remains valid after termination of our relationship with you.
We take all reasonable steps to insure that your personal information is accurate, up-to-date, complete, and reliable for its intended use.
5. LINKS TO NON-POS Corp WEB SITES
6. GLOBAL ORGANIZATION
POS Corp is a global organization, with business processes, management structures, and technical systems that cross borders. Our privacy practices are designed to provide protection for your personal information provided to us all over the world. We may share your personal information within POS Corp and transfer it to countries in the world where we do business. Some countries may provide less legal protection for your information. In such countries, we will still handle your information in the manner described in this policy.
Safe Harbor Compliance
POS Corp is in compliance with the U.S. –EU Safe Harbor Framework and the U.S.-Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, retention and transfer of personal information from European Union member countries and Switzerland to the United States as provided in its certification with the U.S. Department of Commerce. POS Corp has been Self-Certified in accordance with the EU Directive on Personal Data Protection. The principles of Safe Harbor compliance are notice, choice, onward transfer, security, data integrity, access and enforcement Additional information about Safe Harbor principles and certification process can be found at: http://www.export.gov/safeharbor.
In addition, the U.S. Department of Commerce maintains a list of all compliant organizations, which can be accessed at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list.
Members of the European Union
If you are a resident of a Member State of the European Union and have any concerns or complaints, please first address these issues to the Privacy Officer. All matters relating to privacy issues and websites are governed by the laws of the United State and the State of New York. If the Privacy Officer does not satisfactorily address a complaint within thirty (30) days, any dispute, controversy or claim shall be settled by an arbitration administered by an arbitration agency, such as the American Arbitration Association. All arbitrations will be conducted in English. Judgment rendered by the arbitrator may be entered in any court having jurisdiction. All hearings shall be before a single arbitrator. You may also submit complaints to the Federal Trade Commission at http://www.ftc.gov/ftc/complaint.html or via telephone at (202) 382-4537.
7. DISCLOSURES REQUIRED BY LAW
In certain circumstances, it is possible that your personal information may be subject to disclosure by us pursuant to judicial or other government subpoenas, warrants or orders.
8. MERGERS OR ACQUISITIONS
POS Corp may decide to sell, buy, merge or otherwise reorganize businesses, whether for strategic or other business reasons. These business transactions may involve the disclosure of personal information to prospective or actual purchasers or the receipt of personal information from sellers. POS Corp shall seek appropriate protection for your personal information in these types of transactions.
10. CONTACT INFORMATION
You may contact POS Corp’s Privacy Officer to access, correct or delete your personal information. If necessary, the Privacy Officer will contact another employee to assist in completing your requested task.