MBG respects individual privacy and values the confidence of its customers, employees, vendors, business partners and others. MBG strives to collect, use and disclose Personal information in a manner consistent with the laws of the countries in which it does business, and has a tradition of upholding the highest ethical standards in its business practices. MBG abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that MBG follows with respect to transfers of Personal information anywhere in the world, including transfers from the European Economic Area (EEA) (which includes the fifteen member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States.
I. SAFE HARBOR
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable US companies to satisfy the requirement under European Union law that adequate protection be given to Personal information transferred from the EU to the United States. The EEA also has recognized the US Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Consistent with its commitment to protect Personal privacy, MBG adheres to the Safe Harbor Principles.
MBG has a Chief Privacy Officer who is responsible for MBG's compliance with and enforcement of this Policy. MBG's Chief Privacy Officer, Richard Simons, is available to any of its employees, customers, vendors, business partners or others who may have questions concerning this Policy or data security practices. Relevant contact information is provided herein.
II. SCOPE
This Policy applies to all Personal information received by MBG in any format including electronic, paper or verbal. On a global basis, MBG will, establish and maintain business procedures that are consistent with this Policy.
Our privacy statement covers six main areas: Notice, Choice, Onward Transfer, Data Integrity, Security, Access/Correction and Oversight/Enforcement. MBG's privacy practices may vary as required by local laws and policies.
1. Notice
MBG provides this Online Privacy Statement to make you aware of our privacy practices and of the choices you can make about the way your information is collected ( you the individual or the corporation) and used. To make this notice easy to find, we will make it available on our Web homepage at http://mbg-inc.com as of October 1, 2002.
We do not collect any information on our customers as part of the process of accessing any of our products. All information seen in these systems has been provided to us by our customers or, with our customers' approval, by a variety of vendors who provide services to our customers. We use the information supplied by our customers only to provide services which the customer has specifically contracted for. These services provide our customers with a series of tools used to control IT and telecommunications costs.
We do not share information with anyone except as required by law. All customer information is considered to be the customer's property.
2. Choice
MBG operates as a data processor for our customers who fill the role of data collector. MBG maintains only information which our customers have asked us to maintain. It is the customer's responsibility to ensure that it has asked MBG to collect only information that can legally be collected in the country of origin and that it has given its employees the appropriate level of notification that telecommunications data is being collected and maintained.
3. Onward Transfer
MBG does not transfer any information received from its customers to any other party unless explicitly instructed to do so by the customer or as required by law. The location where information is kept may be changed to consolidate data storage and simplify the management of customer information or for disaster recovery purposes. Customers are notified of the location where their data is kept.
4. Data Integrity
MBG will use personal data only in ways compatible with the purposes for which it was collected or subsequently authorized by our customers. MBG will take reasonable steps to ensure that personal information is relevant to its intended use, accurate and complete.
5. Security
MBG 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.
MBG strives to protect the privacy of the information you provide, and inadvertent disclosure of that information is extremely unlikely. In the event of such an inadvertent disclosure, MBG will do everything commercially reasonable to limit and remedy the disclosure, but MBG accepts no liability for any unintentional disclosure. In addition, in the unlikely event that any government or private individual seeks information, MBG will not voluntarily provide the information, but will obey any court order requiring disclosure.
6. Access/Correction
MBG strives to maintain the accuracy of all information kept. All data is displayed in a read-only mode. If you have any questions about the accuracy of any personal telecommunications data we display, please contact the person at your company responsible for maintaining your version of our product. You can also send your request to privacy_advocate@mbg-inc.com.
7. Oversight/Enforcement
MBG privacy practices are self-certified as defined in the U.S. Department of Commerce Safe Harbor Program. For more information about the Safe Harbor Program, please go to http://www.export.gov/safeharbor. In addition, MBG has an internal Customer Privacy Program. It is the charter of this program to ensure appropriate privacy processes are in place in order to meet the practices outlined above.
How MBG Uses Cookies
A cookie is a piece of information either stored temporarily in your browser's memory space (session cookie) or placed on your computer's hard drive (stored cookie). Many stored cookies have a predetermined expiration date after which they disappear from your hard drive or they can be removed explicitly through functionality built into most web browsers. You may set your web browser (e.g. Microsoft Internet Explorer or Netscape Navigator) to notify you of cookie placement requests, ask for permission to accept them, or decline cookies completely.
Session Cookies
Session cookies are used to help us analyze web traffic or to improve your web navigation experience by tracking a unique ID for that particular web site session only. This helps us identify you each time you return to our web site during a browsing session. These cookies are destroyed when you terminate our application or terminate your browsing session by shutting down your browser. Session cookies allow a web application to respond to you as an individual, but without the need to identify you explicitly.
Stored Cookies
MBG uses stored cookies to record user preferences as they relate to our application only. No personal information is stored in these cookies nor is any information extracted from them and permanently stored by MBG.
If you have any questions or comments regarding our online privacy practices, please contact us.
