Last Updated:
8/1/2008
The following describes Connexed's ("Connexed" or the "Company")
privacy policy and the manner in which Connexed handles
information that it receives that may constitute either personal
or sensitive information concerning individuals. Connexed's
intent is to comply with all applicable legal and regulatory
requirements of those jurisdictions in which it does business,
including the Safe Harbor Principles of the European Union
Directive on Data Protection.
Collection of Commercial Information
Connexed collects certain information involuntarily from
visitors to its website, including the IP address, time visited,
pages viewed and related information. The Company also collects
certain information voluntarily when someone sends a direct mail
inquiry, an email or online registration, participates in
seminars or webinars, or requests Company information at
tradeshows. Examples of such information include individual
names, telephone numbers, email addresses, Company name,
person's title, and other personally identifiable information.
Connexed uses such information to monitor the performance, and
improve the quality of, its website, respond to requests about
the Company and its business, provide information about products
and services, fulfill customer requests, marketing and other
business purposes and to comply with various legal and/or
regulatory requirements. The Company may share this information
with business partners to respond to customer needs, or to
engage in joint marketing activities. Connexed may also share
this information with third-party agents who may be acting on
its behalf; e.g., providing notice of an upcoming webinar or
tradeshow that may be of interest to the target audience, or
during solicitation for business purposes.
Collection of Personal and Sensitive Information
Connexed collects personal information only directly from the
individuals affected. Personal information is information that
identifies a particular individual, and does not include
aggregated, compiled or publicly available data. Personal
information that is related to commercial purposes is used as
described in the preceding section. Sensitive information is
personal information that reveals a particular person's: (i)
race; (ii) religion; (iii) ethnicity;(iv) sexual orientation;
(v) political or philosophical beliefs; (vi) trade union
membership; (vii) or information regarding a person's medical
status or condition. Sensitive information is collected solely
for employment-related and other internal business matters, as
well as to comply with legal and regulatory obligations.
Other Uses of Personal and Sensitive Information
In addition to the uses described above, Connexed will inform
individuals of any other intended uses of their personal or
sensitive information at the time such information is collected,
or before such use is implemented, including disclosure to third
parties that are not agents of Connexed. The individual will
have the ability to advise the Company if he/she does not
consent to such intended or additional use (i.e., "opt-in"). For
other personal or commercial information, the individual has the
ability to advise the Company at any time that he/she no longer
wishes to allow such intended or additional use (i.e.,
"opt-out"), again, including disclosure to third parties that
are not agents of Connexed.
Data Security
Connexed will use reasonable methods to secure all personal and
sensitive information by a variety of methods, including
restricting access to such information only to those people who
have a legitimate need to know in order to discharge their job
responsibilities on behalf of Connexed, securing access to the
facility where the information is stored, and the use of
technology and physical controls to secure the information.
Use of Information by Third Parties That are Agents of
Connexed
Connexed will require that all third parties that are acting on
behalf of Connexed, and to which personal or sensitive
information is provided, give Connexed adequate assurances that
they will safeguard all such information in a manner consistent
with both this policy and the Safe Harbor Principles.
Ability to Access and Correct Information
Upon an individual's request, Connexed will provide reasonable
access to any personal or sensitive information it has about
that person. Connexed will also take reasonable steps to allow
such individuals to correct, change, modify or delete any such
information that is shown to be incorrect, inaccurate or
incomplete.
Resolving Disputes
Connexed will investigate any complaints about the use and
disclosure of personal or sensitive information that are not in
accordance with this policy. If Connexed is unable to informally
resolve any such matter to the individual's reasonable
satisfaction, it will participate in the dispute resolution
procedures of the legal or regulatory body having jurisdiction
over the matter (e.g., the Federal Trade Commission), including,
as appropriate, a panel established by the European Data
Protection Authorities, so that disputes are resolved according
to the Safe Harbor Principles.
Enforcement and Compliance
Connexed will conduct regular audits to monitor compliance with
this policy and will provide annual certifications to the U.S.
Department of Commerce that it has done so. Violations of this
policy will subject the violator to disciplinary action, up to
and including termination.
Changes
Connexed may amend or modify this policy from time to time by
posting the amended or modified version on its website at
www.connexed.com. Amendments and modifications will be made in a
manner so as to remain consistent with the Safe Harbor
Principles. This policy may also be changed, or limited, to
comply with legal or regulatory requirements, or as otherwise
allowed or required by law.
Contact Information
Questions or comments about this policy, or concerns or
complaints about possible violations, should be sent to:
Connexed Technologies, Inc.
1010
El Camino Real #250,
Menlo Park, CA 94025
Telephone/Fax: 650-352-6060
