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INTERNATIONAL SOS FOUNDATION
 
CUSTOMER PERSONAL DATA PRIVACY STATEMENT

 
The International SOS Foundation (“ISOSF”) is committed to protecting your
privacy and we encourage you to read this privacy statement.

This statement describes:

 * The personal data that we collect;
 * How we collect data and why
 * How data will be used and who we can disclose or transfer data to and why;
 * How data can be corrected or deleted;
 * The measures that we take to protect data; and
 * The process and contact information that customers can use to raise
   enquiries, concerns and complaints.

1. Commitment to Personal Data Protection

ISOSF is committed to safeguarding your personal data by adherence to the
following obligations:

The ISOSF Data Protection Policy, the Information Security Policy and the
related policies;

 * The United States Government’s Safe Harbor Framework;
 * The Binding Corporate Rules sanctioned by the European Community’s data
   protection authorities; and
 * The relevant local data protection laws and regulations.

The Data Protection Policy and the related policies, the United States Safe
Harbor Principles can be accessed through this following link. The Binding
Corporate Rules will be made available when it has been approved by the data
protection authorities in the European Community.

 
2. What Information is collected and how is it collected?

ISOSF collects personal data about you when you enquire about our activities,
register with us, send or receive a communication or otherwise provide us with
personal information. We may also receive information about you from third
parties, for example from our service providers, that are permitted to share
this personal data. You also provide information to us when you choose to email
data to us, or you participate in promotional initiatives.

“Personal data” includes information that will allow someone to identify or
contact you, including, for example, your full name, address, telephone number
(professional & home) or email address, gender, date of birth, nationality,
family status (dependent), industry sector information related to professional
activity, status (expatriate or traveller) and destinations.

Personal data does not include aggregated data or data that, by itself, does not
permit the identification of individual persons, such as statistics.

ISOSF will only gather data that is relevant for the purposes for which it will
be used and will not gather excessive or unnecessary data.

ISOSF shall take reasonable steps to ensure that data is reliable, accurate,
complete, and current, bearing in mind its intended use. You have a
responsibility to keep the data you provide to us updated and we will take
reasonable steps to facilitate this.

 
3. Acceptance and Links to other Websites

This ISOSF website may contain links to other websites, which are provided
solely as a convenience to you and not as an endorsement by ISOSF of the
contents of other web sites. The other web sites may have their own policies,
which ISOSF does not control, and thus are not addressed or controlled by this
statement or the ISOSF Data Protection Policy.


4. Cookies

A cookie is a piece of data stored on your hard drive containing information
about you. ISOSF uses cookies in order to identify a user session, but usage of
a cookie is in no way linked to any personally identifiable information while on
this ISOSF website.

ISOSF also uses ‘analytical cookies’. These allow us to recognize and count the
number of visitors logging into our web site and to see how visitors move around
the site when they are using it. This helps us make sure sites are meeting
users’ needs and to find out how we could improve.

The analytical cookies do not capture any personally identifiable information.
Most browsers are initially set up to accept cookies. Though most cookies expire
after a certain period of time, you can choose to delete a cookie file at any
time. You can do so by resetting your browser to refuse all cookies or to
indicate when a cookie is sent. However, some ISOSF features or services may not
function properly without cookies.

 
5. How the Personal Data will be used

We will use your personal data:

To, where applicable, provide you with the services, products or information you
have requested; for administration purposes; and to further our charitable aims,
including for fundraising activities.

As part of this, we may analyse the personal information we collect to create a
profile of your interests and preferences so that we can contact you in the most
appropriate way and with the most relevant information.

Your personal data may be transferred to companies within the ISOSF group or to
service providers that are performing services for ISOSF or acting as ISOSF’s
agents. ISOSF will require that any such service providers agree to keep your
personal data secure and confidential, use it only for the purposes for which
the personal data is transferred and use it only in accordance with ISOSF’s
directions.

Your personal data may be transferred to Government authorities, agencies and
institutions as required or permitted by applicable laws and regulations.  ISOSF
shall not collect, use, disclose or transfer your personal data except as
described in this Statement unless you give us your permission to collect, use,
disclose or transfer it for other purposes.

Consent:  By providing personal data to ISOSF you consent to the processing of
such data by ISOSF as described in this Privacy Statement. You can alter your
preferences as described in Clause 7 below.


6. Data Protection for Children

ISOSF does not knowingly collect any information on persons who have not
attained the age of 18 years through the online services and the ISOSF website.


7. Accessing Personal Data

You have the right to ask ISOSF, in writing, for a copy of all the personal data
held about you.  Processing such a request may be contingent on the payment of
an administration fee, your will be advised if such a fee is applicable upon
receipt of your request.  If you would like to access your personal data held by
ISOSF, please apply in writing to privacy@internationalsos.com.

8. Correcting Inaccuracies in Personal Data

In order to update, delete, amend or block any personal information that we
create and that we are able to change, contact us using the following e-mail
address: privacy@internationalsos.com. Should you need our assistance to access
or make changes to your personal information, please submit your request to us.
Corrections or deletions of data resulting solely from errors by ISOSF or our
service providers shall be paid for by ISOSF.

If you do not wish to contact ISOSF via the abovementioned email address, you
may contact our Data Protection Administrators who are also our Country General
Managers, responsible for the country in which you are residing or receiving
products or services. The contact details of the Data Protection Administrators
are attached to this statement.

In making your request to review, update, amend or block data, you will be
required to provide ISOSF with details of the data requested and the reasons why
the data needs correction. ISOSF will ask for proof of your identity. ISOSF may
ask you to assist in verifying the accuracy of the updates and the amendments to
the personal data.

ISOSF may ask you to cover the reasonable cost of accessing and providing copies
of your personal data if this is not provided through the ISOSF website.

ISOSF will strive to address your request as soon as practicable and no later
than thirty (30) calendar days from the date your request is received and
understood.

If ISOSF is asked to destroy the personal data, ISOSF shall use means that
prevents its recreation and ISOSF shall take reasonable care to ensure that
there is no unauthorised disclosure during the destruction of the data.

 
9. What Kind of Security Procedures are Used to Protect the Loss, Misuse, or
Alteration of Your Personal Data under ISOSF’s Control?

ISOSF takes precautions to protect its users’ information. ISOSF has implemented
policies that forbid its employees from using or disclosing personal data in an
inappropriate or unlawful manner and maintains security measures to safeguard
the personal data that it maintains from unauthorized access, misuse,
alteration, loss or destruction.

 
10. How do I Resolve Disputes with ISOSF Relating to Personal  Data?

If you are unsatisfied with the manner in which your question or concern was
addressed, in respect of our online services, you may contact ISOSF at
privacy@internationalsos.com.

ISOSF Online is a licensee of the TRUSTe Privacy Program. TRUSTe is an
independent organization whose mission is to build users’ trust and confidence
in the internet by promoting the use of fair information practices. If you do
not receive acknowledgment of your inquiry or your inquiry has not been
satisfactorily addressed, you should contact TRUSTe at:
http://www.truste.org/consumers/watchdog_complaint.php.

TRUSTe will serve as a liaison with Intl.SOS to resolve your concerns.

If you do not wish to make a complaint through our online services, you may
direct all enquiries, concerns or complaints regarding the collection, use,
storage, correction, deletion, blocking, disclosure or transfer of personal data
to the Data Protection Administrator who is also the ISOSF Country General
Manager, in the country in which you reside or are receiving services using the
contact details attached to this statement.

If you do not receive a satisfactory response from the Data Protection
Administrator you may contact the ISOSF Chief Data Protection Officer, who is
also the General Counsel of ISOSF using the contact details attached to this
statement.

The Chief Data Protection Officer has overall responsibility at ISOSF for
protecting personal data.

ISOSF will investigate all concerns and complaints and will address them
expeditiously. An acknowledgement of the identity of the employee addressing the
complaint and the approximate length of time that will be taken to review the
complaint will be provided no later than five (5) business days from the date
the complaint is received and understood. Regular updates shall be given to you
on the progress of the review if the review is likely to take longer than seven
(7) business days.

You have the right at anytime, to raise your issues with a data protection
authority or to take your case to a court.

If you receive services from ISOSF through an employer or through a relative’s
employer or through an association or institution, or an insurance or financial
services program and your personal information has been improperly collected,
used, stored, disclosed, amended, destroyed, blocked or transferred as a result
of the actions or inactions of the employer, association or institution,
insurance company or financial services company, then you will be directed by
ISOSF to such employer, association or institution, insurance company or
financial services company. ISOSF will not be liable for resolving disputes
between you and such companies, associations or institutions.


11. U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework

ISOSF Assistance complies with the U.S.-EU Safe Harbor Framework and the
U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce
regarding the collection, use, and retention of personal information from
European Union member countries and Switzerland. ISOSF Assistance has certified
that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward
transfer, security, data integrity, access, and enforcement. To learn more about
the Safe Harbor program, and to view ISOSF Assistance’s certification, please
visit http://www.export.gov/safeharbor/
 

12.  Changes to this Statement

ISOSF reserves the right to change this policy at any time by notifying users
through its website of the existence of a new privacy statement. This statement
and the policies outlined herein are not intended to and do not create any
contractual or other legal rights.

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then work. These cookies do not store any personally identifiable information.

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These cookies allow us to count visits and traffic sources through tools
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see how visitors move around the site. Information these cookies collect is
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such as your IP Address, and how you have interacted with our website and
services. If you do not allow these cookies we will not know when you have
visited our site. We will not be able to monitor its performance either.

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These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose
services we have added to our pages. Information shared will often include
information such as your IP Address, and how you have interacted with our
website and services, as well as the third parties offering the relevant
functionality. If you do not allow these cookies then some or all of these
services may not function properly. It may impact your experience.

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TARGETING COOKIES

Targeting Cookies


These cookies may be set through our site by our advertising partners. They may
be used by companies to build your interests profile and show you relevant
adverts on other sites. They do not store directly personal information but are
based on uniquely identifying your browser and internet device. If you do not
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