Company

Privacy Policy

Pedrera, Inc. respects individual privacy and values the confidence of its customers, vendors, consumers, business partners and others. Pedrera, Inc. 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. Pedrera, Inc. abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Pedrera, Inc. follows with respect to transfers of Personal information anywhere in the world, including transfers from the European Economic Area (EEA) 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, Pedrera, Inc. adheres to the Safe Harbor Principles.

Pedrera, Inc. has designated Tim Carter, CEO, the Person responsible for Pedrera's compliance with and enforcement of this Policy. Pedrera, Inc. also has designated Mr. Carter in ensuring compliance with this Policy and data security issues, and he is appointed the safe harbor coordinator for Pedrera, Inc. With the cooperation and assistance of appropriate staff and operating people, he will administrate the company's data protection program, including supporting policies, direct the monitoring and reporting systems and provide regular reports, as appropriate to management. Pedrera, Inc. educates its employees concerning compliance with this Policy and has self-assessment procedures in place to assure compliance. Relevant contact information is provided herein.

 

II. Scope

On occasion, Pedrera, Inc. receives personal information from prospective customers, consumers, vendors, business partners. Such personal information may be maintained at its corporate offices. All Personal information received by Pedrera, Inc. will be used for legitimate business purposes consistent with this Policy.

 

III. Definitions

For purposes of this Policy, the following definitions shall apply:

1. "Agent" means any third party that uses Personal information provided by Pedrera, Inc. to perform tasks on behalf of or at the instruction of Pedrera, Inc.
2. "Pedrera, Inc." means Pedrera, Inc., its predecessors, successors, subsidiaries, divisions and groups.
3. "Personal information" means any information or set of information that identifies or could be used by or on behalf of Pedrera, Inc. to identify an individual. Personal information does not include information that is encoded or publicly available information that has not been combined with non-public Personal information.
4. "Sensitive Personal information" means Personal information that reveals race, ethnic origin, trade union membership, or that concerns health. In addition, Pedrera, Inc. will treat as sensitive Personal information, any information received from a third party, where that third party treats and identifies the information as sensitive.

IV. Privacy Principles

The privacy principles in this Policy are based on the seven Safe Harbor Principles.

1. NOTICE: Where Pedrera, Inc. collects Personal information directly from individuals, 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 Pedrera, Inc. discloses that information, and the choices and means, if any, Pedrera, Inc. offers individuals for limiting the use and disclosure of their Personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal information to Pedrera, Inc., or as soon as practicable thereafter, and in any event before Pedrera, Inc. uses the information for a purpose other than that for which it was originally collected. Pedrera, Inc. may disclose Personal information if required to do so by law or to protect and defend the rights or property of Pedrera, Inc.
2. CHOICE: Pedrera, Inc. 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, Pedrera, Inc. 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. Pedrera, Inc. will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.
3. DATA INTEGRITY: Pedrera, Inc. will use Personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Pedrera, Inc. will take reasonable steps to ensure that Personal information is relevant accurate, complete and current, to its intended use.
4. TRANSFERS TO AGENTS: Pedrera, Inc. 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), Safe Harbor certification by the Agent, or being subject to another European Commission adequacy finding (e.g., companies located in Hungary and Switzerland). Where Pedrera, Inc. has knowledge that an Agent is using or disclosing Personal information in a manner contrary to this Policy, Pedrera, Inc. will take reasonable steps to prevent or stop the use or disclosure. Pedrera, Inc. holds its Agents accountable for maintaining the trust our employees and customers place in the company.
5. ACCESS AND CORRECTION: Upon request, Pedrera, Inc. will grant individuals reasonable access to Personal information that it holds about them. In addition, Pedrera, Inc. will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.
6. SECURITY: Pedrera, Inc. will take reasonable precautions to protect Personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Individuals who have been granted access to Personal information will be made aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so.
7. ENFORCEMENT: Pedrera, Inc. will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy and the US Department of Commerce Safe Harbor Principles. Any employee that Pedrera, Inc. determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.

V. Dispute Resolution

Any questions or concerns regarding the use or disclosure of Personal information should be directed to Pedrera, Inc. at the address given below. Pedrera, Inc. will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Pedrera, Inc. and the complainant, Pedrera, Inc. has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.

 

VI. Internet Privacy

Pedrera, Inc. sees the Internet, intranets and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, vendors, business partners and others. Pedrera, Inc. recognizes the importance of maintaining the privacy of Personal information collected through websites that it operates. Pedrera's sole purpose for operating its websites is to provide information concerning products and services to its customers and employees. In general, visitors can reach Pedrera, Inc. on the Web without revealing any Personal information. Visitors on the Web may elect to voluntarily provide Personal information via Pedrera, Inc. websites but are not required to do so. Pedrera, Inc. collects information from visitors to the websites who voluntarily provide Personal information by filling out and submitting online questionnaires concerning feedback on the website, requesting information on products or services, or seeking employment. The Personal information voluntarily provided by website users is contact information limited to the user's name, home and/or business address, phone numbers and email address. Pedrera, Inc. collects this information so it may answer questions and forward requested information. Pedrera, Inc. does not sell or share this information with non-agent third parties. For purposes of improved security and authentication, Pedrera may enter into mutual agreements with customers or partners to utilize protocols and technology that may require the collection of additional information.

Pedrera, Inc. may also collect anonymous information concerning website users through the use of "cookies" in order to provide better customer service. "Cookies" are files that websites place on users' computers to identify the user and enhance the website experience. None of this information is reviewed at an individual level. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies. If visitors do so, however, some areas of Pedrera, Inc. websites may not function properly.

Pedrera, Inc. website users have the option to request that Pedrera, Inc. not use information previously provided, correct information previously provided, or remove information previously provided to Pedrera. Those that would like to correct or suppress information they have provided to Pedrera, Inc. should forward such inquiries to:

Pedrera, Inc.
Email: info@pedrera.com
C/O Safe Harbor Compliance
95 West Court Street
Doylestown, PA 18901

The inquiries should include the individual's name, address, and other relevant contact information (phone number, email address). Pedrera, Inc. will use all reasonable efforts to honor such requests as quickly as possible. Pedrera, Inc. websites may contain links to other "non-Pedrera" websites. Pedrera, Inc. assumes no responsibility for the content or the privacy policies and practices on those websites. Pedrera, Inc. encourages all users to read the privacy statements of those sites; their privacy practices may differ from those of Pedrera.

 

VII. Changes to This Safe Harbor Privacy Policy

The practices described in this Policy are current Personal data protection policies as of January 11, 2005. Pedrera, Inc. reserves the right to modify or amend this Policy at any time consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such amendments.