1.0 Introduction
The purpose of this document is to inform you about the type of information
that ASI Group (ASI) gathers on individuals that utilize its electronic
services, how it uses this information, whether it is disclosed to any third
parties, your ability to modify/remove said information and how that
information is protected.
1.1 Effective Date
The Effective Date of this Privacy Policy is
April 1, 2008.
1.2 Changes to ASI Privacy Policy
In accordance with the California Online
Privacy Protection Act of 2003, ASI has created a Privacy Policy Update Log
("PPUL"). The PPUL constitutes a public notification mechanism to
announce changes to this policy document. The PPUL will note the date of any
change to the ASI Privacy Policy and document the nature of the change. The
PPUL will only document changes after June 30, 2004. Consumers may access the
PPUL by visiting the following URL: http://www.asigroup.com/privacy_policy_blog.htm
2.0 Personal Information Collection and
Usage
ASI collects, stores and may use information gathered on individuals that
utilize its Internet-based and/or email-based services. The extent of the
information gathered and/or used may vary widely based on the information
service utilized by the individual. In all circumstances, ASI may collect and
possibly share information in order to investigate, prevent, or take action
regarding illegal activities, situations creating potential threats to the
physical safety of any person, suspected fraud, violations of ASI's terms of
use, or as otherwise required by law. ASI may respond to subpoenas, court
orders, or legal process and may choose to establish or exercise its legal
rights or defend against legal claims.
Airline Insider
Information gathered on users of the Airline
Insider is utilized for statistical monitoring of session usage and legal
purposes on behalf of ASI, its designated agents and/or affiliates and/or
the organization that holds the subscription. This information will not be
used for marketing purposes or sold/transferred to third-parties for
marketing purposes. Archived information regarding session usage may be
stored for an extended period of time. At any time, the organization that
holds the subscription to the service may request information for its use
for internal purposes. ASI shall not be responsible for actions related to
information used for internal purposes.
ASI Essentials
Information gathered on users of ASI
Essentials is utilized for statistical monitoring of session usage and legal
purposes on behalf of ASI, its designated agents and/or affiliates and/or
the organization that holds the subscription. This information will not be
used for marketing purposes or sold/transferred to third-parties for
marketing purposes. Archived information regarding session usage may be
stored for an extended period of time. At any time, the organization that
holds the subscription to the service may request information for its use
for internal purposes. ASI shall not be responsible for actions related to
information used for internal purposes.
ASI Travel Security Manager
The ASI Travel Security Manager (TSM) is a
service jointly provided by ASI and Control Risks (CRG). The TSM Website and
all data collection is performed by CRG, which is acting as a designated
agent of ASI. Please see the CRG Privacy Statement (http://www.control-risks.com/default.aspx?page=35)
regarding the types of data collected and stored by CRG. ASI does not
directly collect or store any personally identifiable information with
regard to the TSM service. ASI may have access to view personally
identifiable information through the TSM service for consulting purposes to
the organization that holds the subscription. In such cases, however, prior
written permission of the organization that hold the subscription is
required. This information will not be used for marketing purposes or
sold/transferred to third-parties.
HOT SPOTS
HOT SPOTS is a free subscription-based
briefing report sent via email Monday through Friday. Subscriptions are
initiated only by request by the individual. Third-party requests to add an
individual to the HOT SPOTS mailing lists will not be accepted. The
individual requesting the subscription is required to actively supply
certain information to ASI before a subscription request will be accepted.
This information includes, but is not limited to: Name, Organization Name,
Address, City, State, Postal Code, Country, Telephone Number, Fax Number,
and E-Mail Address. Individuals should be aware, however, that failure to
submit required information or the provision of incomplete information may
preclude ASI from initiating a subscription to the HOT SPOTS report. Under
no circumstances is this information sold or otherwise transferred to a
third-party. Individuals acting in a business capacity may receive a
marketing-related email from ASI upon submission of their subscription
request. In addition, individuals acting in a business capacity may have
their personal business information stored in retrievable form by ASI for an
extended period of time. Individuals may request to review, change, or
remove personal information that is stored in retrievable form in ASI’s
databases by following the processes set out in Section 5.0 of this
document. Subscribers the HOT SPOTS mailing list may receive occasional
marketing-related e-mail messages from ASI. At any time, a subscriber to HOT
SPOTS may request a change to their HOT SPOTS subscription (e.g.: email
address change) or removal (opt-out) from the HOT SPOTS mailing list by
sending an email to hotspots@asigroup.com
or by formal written letter to:
HOT SPOTS
ASI Group
2925 Briarpark, Suite 1100
Houston, Texas 77042
World Watch® Online
Information gathered on users of World Watch®
Online is utilized for statistical monitoring of session usage and legal
purposes on behalf of ASI, its designated agents and/or affiliates and/or
the organization that holds the subscription. This information will not be
used for marketing purposes or sold/transferred to third-parties for
marketing purposes. Archived information regarding session usage may be
stored for an extended period of time. At any time, the organization that
holds the subscription to the service may request information for its use
for internal purposes. ASI shall not be responsible for actions related to
information used for internal purposes. In extremely limited cases, the
holder of the subscription may require the entry of an employee
identification number at time of login. In such circumstances, ASI provides
the holder of the subscription details on individual user sessions such as
areas of the site visited (e.g. country and city files viewed).
Information Requests via ASI Website or Email
ASI may utilize personal information actively submitted to its public
Websites for marketing purposes. This information may include, but is not
limited to: name, address, title, employee number, telephone number, fax
number and email address. Individuals acting in a business capacity may have
their personal business information stored in retrievable form by ASI for an
extended period of time. Individuals may request to review, change, or
remove personal information that is stored in retrievable form in ASI’s
databases by following the processes set out in Section 5.0 of this
document. Under no circumstance shall ASI sell or transfer personal
information actively entered to its public Websites to a third-party for
marketing purposes. Individuals that do not wish to share personal
information should not actively submit such information to ASI. Individuals
should be aware, however that failure to submit required information or the
provision of incomplete information may preclude ASI from fulfilling a
particular request.
3.0 Security
ASI is committed to ensuring the security of
your information. To prevent unauthorized access or disclosure, maintain data
accuracy, and ensure the appropriate use of information, we have put in place
appropriate physical, electronic, and managerial procedures to safeguard and
secure the information we collect online. We use encryption when collecting or
transferring sensitive data such as travel reservations.
4.0 Transfer and Access of Data
Personal information gathered by ASI through
its public and subscription-based Websites may be transferred across state or
country borders. All such data transfers shall be in accordance with the terms
outlined in this document.
5.0 Review, Modification and Removal of Data
An individual may request to review, change, or
remove personal information that is stored in retrievable form in ASI’s
databases by formal written request to ASI. Information is considered to be in
retrievable form when it is "retrievable in the ordinary course of
business" by taking steps that are taken on a regular basis in the
conduct of ASI’s business activities with respect to that information, or
that ASI is capable of taking with the procedures it uses on a regular basis
in the conduct of its business.
Formal written requests for review, change or
removal of personal information should be directed to:
Privacy Issues
ASI Group
2925 Briarpark, Suite 1100
Houston, Texas 77042
6.0 Safe Harbor and Enforcement
ASI is an adherent to the safe harbor framework
developed by the U.S. Department of Commerce in coordination with the European
Commission. The safe harbor framework provides guidance for U.S.
organizations on how to provide "adequate protection" for personal
data from Europe as required by the European Union's Directive on Data
Protection. ASI undergoes an annual privacy policy review and
self-certification process as part of its adherence to the safe harbor
principles.
Under the Safe Harbor's Enforcement Principle,
organizations self-certifying to Safe Harbor must establish an independent
recourse mechanism available to investigate unresolved complaints. ASI has
chosen to utilize the European Data Protection Authorities (DPA) in
fulfillment of the Enforcement Principle. This means that ASI commits to
cooperate with the DPAs in the investigation and resolution of complaints
brought under the safe harbor. In addition, ASI agrees to comply with
any advice given by the DPAs with regard to specific action(s) needed to
comply with the Safe Harbor Principles, including remedial or compensatory
measures for the benefit of individuals affected by any non compliance with
the principles.
7.0 Use of “Cookies”
A “cookie” is a piece of information stored
temporarily in an individual’s browser memory space or placed on the
individual computer's hard drive (stored cookie). Cookies may be used in some
circumstances on some information systems, but are not used for marketing
purposes by ASI, its designated agents and/or affiliates. Cookies utilized by
ASI are not used to track usage outside of ASI Websites.
8.0 Third-Party Websites
Links to third-party Websites are provided as a
convenience to the user. When linking to a third-party Website, the user will
leave the system administered by ASI. Control and content of third-party
Websites are provided by the owner of that Website and not ASI. ASI does not
endorse or make any representation regarding third-party Websites and cannot
be held responsible for content, control or usage in any manner whatsoever.
Use of third-party sites should be done entirely at the user’s own risk.
9.0 Questions / Comments
Questions or comments on data privacy or data security issues with specific
regard to the TSM product and Control Risks should be directed to webmaster@control-risks.com.
Informal questions or comments regarding ASI’s online privacy practices
should be directed to privacy-issues@asigroup.com
Questions or comments requiring a formal response from ASI should be directed
to:
Privacy Issues
ASI Group
2925 Briarpark, Suite 1100
Houston, Texas 77042
