EU-US Data Privacy Framework (EU- US DPF), the UK Extension to the EU-US DPF & the Swiss-US Data Privacy Framework Policy

 

SPK and Associates, LLC., as part of its privacy policy, complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. SPK and Associates has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) regarding the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  SPK and Associates has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) regarding the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit Data Privacy Framework website.

• SPK and Associates is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
• Pursuant to the Data Privacy Framework, SPK and Associates remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
• EU, UK and Swiss individuals have the right to access their data and to correct, update or amend incorrect information. The individuals can also request erasure of data that has been handled in violation of the DPF If you would like access to any personal information you have submitted, please contact SPK at: info@spkaa.com. (Please note that as a data processor, we may need for forward any requests to the appropriate data controller to be accommodated.)
• SPK does not rent, sell, or share personal data for reasons other than those for which it was originally provided to If this practice should change in the future, we will update this policy accordingly and provide individuals with opt-in or opt-out choice as necessary.
• We may be required to release an individual’s personal information in response to lawful requests by public authorities including to address national security or law enforcement concerns.

 

In compliance with the EU-US Data Privacy Framework (EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) SPK commits to resolve complaints about your privacy and our collection or use of your personal information. European Union, United Kingdom, and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact SPK at: us-privacy@spkaa.com.

SPK has further committed to refer unresolved privacy complaints under the Data Privacy Framework to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by SPK, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

 If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset- 35584=2

 

SPK’s Internet Privacy Commitment

 

Data collection

We collect only personally identifiable information that is specifically and voluntarily provided by visitors to SPK’s website. SPK receives limited identifiable information, such as name, title, company address, email address, telephone, and fax numbers from website visitors. Typically, identifying information is collected to:

 

• Register for certain areas of the site
• Inquire for further information
• Distribute requested reference materials
• Submit resumes

 

It is SPK’s policy to limit the information collected to only the minimum information required to complete a visitor’s request. In any instance where non-mandatory information is sought, the website visitor will be notified of this at the point of collection. 

As a policy, visitors are not required to register to gain access to areas of the SPK websites. In certain cases, in the future, as your SPK website experience expands, we may require visitors to register in order to obtain a user-id and password for authentication and secure access to a transaction or certain business confidential or proprietary information services on premium websites.

Personally identifiable information provided to SPK through its website is provided voluntarily by visitors. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate website area or in communications to our visitors.

Although most publications are provided as free downloads, we do offer the opportunity to purchase SPK publications either online or by calling our toll- free number. Customers pay by check and no credit card information is collected.

 Visitors are also able to send email through the site. Their messages will contain the user’s screen name and email address as well as any additional information the user may wish to include in the message. Because we use the website as a recruiting tool, a visit to the website may also result in the user sending a resume to an individual within SPK.

EU, UK and Swiss individuals whose data we receive can address questions or comments regarding the handling of that information directly to us at privacy@spkaa.com. We resolve to deal with all questions regarding this data and potential grievances arising from it in a timely manner. Note that under certain conditions we may, as a data processor, refer you to our client who is the data controller. 

SPK’s intention is not to seek any sensitive information through our website unless legally required for recruiting purposes. If you do wish to provide sensitive information for any reason, SPK accepts your explicit consent to use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

 

Use of data

A user may choose to provide personal information in the following examples:

• Order publications
• Submit resumes or work history information
• Participate in “join our mailing list” initiatives
• Participate in bulletin boards, discussion or message forums
• Contact us for further information
• Enter Quick Surveys, Quiz’s, or Benchmarking Surveys
• Register for events and conferences

If you would like to find out more about the different categories of information collected, please review the data collection section.

SPK makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the site has collected excessive information, we encourage the visitor to contact us at: info@spkaa.com to raise any concerns.

Cookies and log files

Cookies may be used on some pages of our site. “Cookies” are small text files placed on your hard drive that assist us in providing a more customized website experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area. It is SPK’s policy to use cookies to make navigation of our website easier for visitors and to facilitate efficient registration procedures. Site statistics are compiled by third parties, and therefore your IP address will be passed to third parties for statistical reporting only.

If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully

navigate our websites; however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

In order to properly manage our website we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters. This is to ensure that our website presents the best web experience for visitors and is an effective information resource.

 

Third parties

 

It is SPK’s policy only to disclose information to third parties under the following circumstances:

• As required by law through subpoena, search warrant or other legal process
• When explicitly requested by a visitor
• When required to deliver publications or reference materials requested by a visitor
• When required to facilitate conferences or events hosted by a third party

SPK’s policy is to disclose information to third parties upon visitors submitting their requests (e.g., when ordering a publication, we display the party fulfilling the order).

SPK websites do not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties. If this practice changes in the future, SPK will update this privacy policy and provide individuals with an opt-out choice.

 

Third-party links

 

There are several places throughout spkaa.com that may link to other websites that do not operate under spkaa.com’s privacy practices. When you link to other websites, SPK’s privacy practices no longer apply. We encourage visitors to review each site’s privacy policy before disclosing any personally identifiable information.

 

Data retention

 

Some of the information we receive is not retained. Contact information about visitors (such as information generated though registration for access to areas on the site) will be kept as long as the information is required to completely service the contact request or until a user requests that we delete that information. Mailing list information, discussion posts and email are kept for only the period of time considered reasonable to facilitate the visitor’s requests. Resumes are disposed of when they are either no longer under consideration or are considered dated by our Human Resources departments.

 

Choices

 

Information obtained by the site is used only for the intended purpose stated at the time that the information is collected. This data is not shared with other entities in the network for secondary or unrelated purposes or shared with non-agent third parties, unless otherwise disclosed at the point of collection. If there is an instance where such information may be shared, the visitor will be asked for permission beforehand.

 

Access

 

Each visitor has the right of access to personal data they have submitted through SPK’s website. If you would like access to any personal information you have submitted, please contact SPK at: info@spkaa.com.

SPK is committed to providing reasonable and practical access to visitors to allow them the opportunity to identify and correct any inaccuracies. When requested and practical, SPK will delete identifying information from current operational systems.

When personally identifiable information is retained, SPK assumes responsibility for keeping an accurate record of the information once a visitor has submitted and verified the data. SPK does not assume responsibility for verifying the ongoing accuracy of the content of personal information. When practically possible, if SPK is informed that any personal data collected through a website is no longer accurate, SPK will make appropriate corrections based on the updated information provided by the authenticated visitor.

 

Security

 

SPK has implemented generally accepted standards of technology and operational security to protect personally identifiable information from loss, misuse, alteration, or destruction. All SPK employees follow a network-wide security policy. Only authorized SPK personnel are provided access to personally identifiable information and these employees have agreed to ensure confidentiality of this information. SPK’s policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. This policy is also required for any fulfilment agents of our firms.

Children

 

SPK understands the importance of protecting children’s privacy especially in an online environment. The SPK sites covered by this privacy statement are not intentionally designed for or directed at children 13 years of age or younger. It is SPK’s policy never to knowingly collect or maintain information about anyone under the age of 13.

 

Modifications

 

SPK reserves the right to modify or amend this Statement at any time. The effective date will be displayed at the beginning of this statement. To keep visitors informed, SPK will notify users of changes to our Privacy Statement by prominently identifying the alteration for a period of not less than two weeks on our global home page at www.spkaa.com.