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POOL4TOOL Safe Harbor Privacy Statement


I. Declaration

POOL4TOOL respects individual privacy and values the confidence of its customers, employees, consumers, business partners, and others. POOL4TOOL abides by and is in compliance with the Safe Harbor Principles set forth in the U.S.-EU Safe Harbor Framework developed by the U.S. Department of Commerce and the European Commission (“Safe Harbor Principles”). POOL4TOOL pledges and certifies its compliance with Safe Harbor Principles, and is committed to collecting, storing, using and disclosing personal information  in compliance with the laws of the countries in which it does business. This Safe Harbor privacy statement (“Privacy Statement”) supplements the POOL4TOOL Privacy Policy.

To learn more about the Safe Harbor program please visit and to view the certification for POOL4TOOL America, LLC, visit <wbr />list.aspx

II. Definitions

For purposes of Privacy Statement, the following definitions shall apply:

1.  "POOL4TOOL" means POOL4TOOL America LLC, 34119 W. Twelve Mile Road, Suite 320, Farmington Hills, MI 48331 of the United States of America (USA).

2. "Personal Information" means any information or set of information transferred  by POOL4TOOL from or to the EEA (European Economic Area) that identifies or could be used by or on behalf of POOL4TOOL or its customers to identify an individual covered by the Safe Harbor Framework. It can include but is not limited to a person’s name and information associated with his or her personal identity as opposed to information associated with a business, such as name, business address, business email, individually used corporate credit card number, etc. Personal Information does not include information that is encoded or publicly available information that has not been combined with non-public Personal Information.

3. "Sensitive Personal Information" means Personal Information that reveals for example race, medical or health conditions, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, government identification numbers or financial account numbers associated with individual persons (e.g. US Social Security numbers, driver’s license numbers, or personal credit card or banking account numbers) .

4.  "Third Party" means any person that is not an employee or a subsidiary of POOL4TOOL.

5. "Customer" means a Third Party, on whose behalf and whose directions that POOL4TOOL provides data processing and other professional services.

III. Personal Information

This Privacy Statement applies to all Personal Information and Sensitive Personal Information received by POOL4TOOL in any format and from any sources including electronic, paper or verbal.

POOL4TOOL collects, receives, and processes Personal Information from current and former employees and their respective as well as applicants for employment, Customers, prospective Customers, Customers’ end users (including, but not limited to customers’ employees and customers).

All the information collected by POOL4TOOL is POOL4TOOL property. All the Customer data is Customer’s property.  All POOL4TOOL data and Customer data are guarded with security and integrity as proprietary.

All Personal Information collected or received by POOL4TOOL will be used for legitimate business purposes in consistency with and in compliance with this Privacy Statement.   POOL4TOOL will not sell or share any of the Personal Information with Third Parties in ways different than what is disclosed in this Policy.

IV. Privacy Principles

The privacy principles in this Privacy Statement are developed in compliance with the Safe Harbor Principles by meeting the requirements of the seven Safe Harbor principles.  Where a conflict exists between the provisions of this Privacy Statement and the Safe Harbor principles, the Safe Harbor Principles will govern.

1. Notice  
When Personal Information is collected by POOL4TOOL, POOL4TOOL will notify individuals about the purposes for which it collects and uses information about them. POOL4TOOL will provide information about how individuals can contact POOL4TOOL with any inquiries or complaints, the types of Third Parties to which it discloses the information and the choices and means the organization offers for limiting its use or/and disclosure.

2. Choice  
On its own or on behalf of and in consistent with its Customer’s direction, POOL4TOOL will give individuals the opportunity to choose (opt out) whether their Personal Information will be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, if any, affirmative or explicit opt in)choice will be given if the information is to be disclosed to a third party or used for a purpose other than its original purpose or the purpose authorized subsequently by the individual.

3. Onward Transfer (Transfers to Third Parties) 
To disclose information to a third party, POOL4TOOL will apply the notice and choice principles. Where an organization wishes to transfer information to a Third Party that is acting as an agent, it will make sure that the Third Party subscribes to the Safe Harbor principles or is subject to the European Directive or another adequacy finding. Or as an alternative, POOL4TOOL will enter into a contractual agreement with such Third Party requiring that the Third Party provides at least the same level of privacy protection as is required by the Safe Harbor principles.

4. Access  
POOL4TOOL guarantees individuals to access to the Personal Information about them that POOL4TOOL holds and be able to correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question, or where the rights of persons other than the individual would be violated.

5. Security
POOL4TOOL will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. POOL4TOOL limits access to Personal Information to those persons for legitimate and specific business reasons and on basis of need to know.  Any individuals who are granted access to Personal Information will have been made aware of their responsibilities to protect the security, confidentiality, and integrity of that information and will have been provided with training and instructions on how to do so in compliance with POOL4TOOL’s data security and privacy policy, including this policy.

6. Data Integrity 
POOL4TOOL will take reasonable efforts to ensure that data is reliable for its intended use, accurate, complete, and current.

7. Enforcement  
POOL4TOOL will conduct annual compliance audits of its relevant data security and privacy policies and practices to verify its adherence to this Policy and the Safe Harbor Principles. Any employee that POOL4TOOL determines is in violation of this Privacy Statement will be subject to disciplinary action up to and including termination of employment. Any Third Party that violates this Privacy Statement shall be in material breach of all agreements with POOL4TOOL and shall defend and indemnify POOL4TOOL from claims related to such violations.

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to POOL4TOOL Privacy Coordinator. POOL4TOOL will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Statement.

POOL4TOOL agrees to participate in the dispute resolution procedures of the panel established by the European Union data protection authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles. The EU DPAs may be contacted directly via the information provided at or contact the panel secretariat at: . Mail address: Data protection panel secretariat, 100 avenue de Cortenbergh, B-1040 Brussels, BELGIUM.

V. Effective Date and Changes  

The practices described in this Privacy Statement are the current Personal Information protection policies as of February 28, 2014. It shall be posted on POOL4TOOL website at POOL4TOOL reserves the right to modify or amend this Privacy Statement at any time consistent with the requirements of the Safe Harbor principles and post the revised version on this website.

VI. Privacy Coordinator and Contact Information

POOL4TOOL has information security infrastructure, procedures and policies, and best practices in place to provide secured data privacy protection for individuals and businesses as well.

POOL4TOOL educates, trains, and mandates its employees’ awareness most likely to be in possession of or accessing Personal Information concerning compliance with this Privacy Statement and to assure compliance.

The Privacy Coordinator is available to any of its valued employees, customers, vendors, business partners or others who may have questions concerning this Policy or data security practices. Questions or complaints regarding this Privacy Statement and any privacy-related issue should be submitted by mail or email to attn.: POOL4TOOL Privacy Coordinator, or send written correspondence to:

POOL4TOOL Privacy Coordinator |  POOL4TOOL America, LLC | 34119 W. Twelve Mile Road | Suite 320 | Farmington Hills,  MI 48331 | United States of America


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