The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the "U.S.-EU Safe Harbor"). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, SMART LIVING, LLC adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, SMART LIVING, LLC or to which SMART LIVING, LLC discloses personal information for use on SMART LIVING, LLC behalf.
“SMART LIVING LIMOUSINE OR SMART LIVING SPRINTER” means SMART LIVING, LLC its predecessors, successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of SMART LIVING, LLC to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, SMART LIVING, LLC will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
NOTICE: Where SMART LIVING, LLC collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which SMART LIVING, LLC discloses that information, the choices and means, if any, MTC Limousine offers individuals for limiting the use and disclosure of personal information about them, and how to contact SMART LIVING, LLC. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to SMART LIVING, LLC, or as soon as practicable thereafter, and in any event before SMART LIVING, LLC uses or discloses the information for a purpose other than that for which it was originally collected.
Where SMART LIVING, LLC receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
CHOICE: SMART LIVING, LLC will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, SMART LIVING, LLC will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
SMART LIVING, LLC will provide individuals with reasonable mechanisms to exercise their choices.
RESERVATIONS: If you make reservations or purchase a product or service from us, we request certain personally identifiable information from you at the time of booking. You must provide contact information (such as name, email, and address) and financial information (such as credit card number, expiration date).
We use this information for billing purposes and to process your reservations. If we have trouble confirming your reservations, we will use this information to contact you.
DATA INTEGRITY: SMART LIVING, LLC will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. SMART LIVING, LLC will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: SMART LIVING, LLC will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where SMART LIVING, LLC has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, SMART LIVING, LLC will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, SMART LIVING, LLC will grant individuals reasonable access to personal information that it holds about them. In addition, SMART LIVING, LLC will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: SMART LIVING, LLC has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorized SMART LIVING, LLC personnel are provided access to personally identifiable information and these employees have agreed to ensure confidentiality of this information. SMART LIVING, LLC's policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. www.mtclimousine.com is using a 256-bit SSL certificate from Trustwave. This SSL Certificate provides encryption of personal information transmitted over the Internet securely.
ENFORCEMENT: SMART LIVING, LLC will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that SMART LIVING, LLC determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the SMART LIVING, LLC Privacy Office at the address given below. SMART LIVING, LLC will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between SMART LIVING, LLC and the complainant, SMART LIVING, LLC has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:
1. for disputes involving all personal information received by SMART LIVING, LLC from UNITED STATES, SMART LIVING, LLC has agreed and to cooperate with the UNITED STATES FDPIC;
2. for disputes involving employment-related personal information received by SMART LIVING, LLC from the EEA, SMART LIVING LLC has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
3. for disputes involving all other personal information received by SMART LIVING, LLC from the EEA, MTC Limousine has agreed to Privacy Trust dispute resolution. Individuals who submit a question or concern to SMART LIVING, LLC and who do not receive acknowledgment from SMART LIVING, LLC of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the Privacy Trust Safe Harbor Dispute Resolution Program on the Internet, by mail or by fax. Inquiries by mail or fax should identify SMART LIVING, LLC as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether Privacy Trust may share the details of the inquiry with SMART LIVING, LLC. Privacy Trust will act as a liaison to SMART LIVING, LLC to resolve these disputes.
- a. [email protected]
- b. Mail: SMART LIVING, LLC | 1728 S. CATALINA AVE. #2 | REDONDO BEACH, CA 90027
- For information about Privacy Trust or the operation of Privacy Trust's dispute resolution process, visit Privacy Trust on the Internet or request this information from Privacy Trust by mail or fax using the contact information listed above. The Privacy Trust dispute resolution process shall be conducted in English.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by SMART LIVING, LLC to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Questions or comments regarding this Policy should be submitted to SMART LIVING, LLC by mail to:
SMART LIVING, LLC
1728 S. CATALINA AVE
REDONDO BEACH, CA 90027
Or by e-mail to [email protected]
EFFECTIVE DATE: JANUARY 30, 2017