TPUSA, Inc., Privacy
TPUSA, Inc. ("TPUSA"), recognizes and respects the importance of
protecting individuals' personally identifying information
applies to all Personal Information that TPUSA collects or receives
from or through the performance of services for its clients outside
the United States and transfers into the United States, whether
manually or digitally processed. The Policy governs TPUSA and each
of its subsidiaries.
2. Our Services. TPUSA provides
contact center management services ("Services") for clients located
around the globe. The clients retain TPUSA to transmit messages and
to provide information to their customers and others
("Recipients"). In other cases, TPUSA may collect Personal
Information from Recipients when Recipients are asked to provide or
to verify Personal Information in order to obtain goods or
services. In all cases, we simply act as agent for our clients and
at their direction. We rely on our clients to comply with all
applicable personal-data privacy laws in compiling and providing us
with the Recipient information.
3. Other Information Collection.
We also may collect Personal Information when clients or Recipients
contact us with a question or concern about this Policy or about
our Services. If Personal Information is provided to TPUSA in this
context, we will use it only to respond to a specific inquiry or
otherwise as required by law.
4. Transfer of Personal
Information. As noted above, we utilize the
Personal Information of Recipients only as directed by our clients
in the performance of the Services. We do not disclose Personal
Information of Recipients to third parties except to our clients or
to authorized service providers - which may be affiliated or
nonaffiliated companies - who assist us in performing the Services,
unless otherwise required by law. Because we simply process the
information provided to us, our clients remain responsible for that
Personal Information with respect to the individuals concerned.
5. Access to Personal Information.
Individuals seeking access to Personal Information that we receive
from our clients should contact the client directly. All of TPUSA's
messages should prominently display the name of the client on whose
behalf the message was sent. We also would be happy to provide any
interested Recipient the applicable client's name and contact
information. Individuals seeking access to Personal Information
about themselves that we have collected must contact our Privacy
Compliance Officer as directed below. We will make reasonable
efforts to provide the requested information promptly if it is
still available to us, although we reserve the right to charge the
requester for the cost (in time and expenses) of retrieval.
6. Security. We utilize reasonable
and appropriate protections to ensure that Personal Information in
our care is not misused or accessed without authorization. Personal
Information is stored on our own servers, with access restricted to
those clients to which the Personal Information in question relates
and to employees or contractors who have a need for such access to
perform a legitimate business purpose relating either to the
Services or to maintenance, internal security or related issues.
Moreover, we generate audit logs that record all access and use of
Recipients' Personal Information stored in our databases. Any
contractor whom we retain to provide services for us and who will
have access to Personal Information must agree in writing to abide
by the terms of this Policy.
7. Data Integrity. We only use
Personal Information that is necessary to perform the Services
requested. Occasionally, a client provides us with more Personal
Information than is necessary (for example, providing us with a
name, street address and e-mail address, when only the name and
e-mail address are necessary). In those cases, we employ automated
programs (or manual procedures in the case of difficulty) that
identify and utilize only those data that are needed. The rest
remain secure and unused until destroyed or returned to the client.
We also only store Personal Information when specifically requested
to do so by a client or as part of our ordinary back-up, archiving
process. Archived files are secured consistent with paragraph 6
above and are destroyed on a regular cycle.
8. European Union and Switzerland Safe Harbor
Compliance. To the extent that it impacts Personal
Information transferred from a European Economic Area ("E.E.A.")
nation to the United States, or Switzerland to the United States,
and as more fully detailed above, this Policy complies with all
applicable principles of the U.S. - E.U. Safe Harbor and with all
applicable principles of the U.S. - Switzerland Safe Harbor. TPUSA
has certified its participation in both Safe Harbor frameworks with
the United States Department of Commerce.
9. Enforcement. Concerns regarding
our adherence to this Policy should be raised first with our
Corporate Privacy Officer as directed below in paragraph 13.
TPUSA's compliance with this Policy is subject to the ultimate
authority of the United States Federal Trade Commission, to which
complaints that are not adequately resolved through the above
avenue also may be directed.
10. Acquisition, Merger or
Bankruptcy. In the event TPUSA or any of its
affiliates or subsidiaries is acquired by another entity or merges
with a third party, the successor entity will be bound to respect
the provisions of this Policy with regard to any Personal
Information in TPUSA's (or its affiliates' or subsidiaries')
possession prior to the acquisition or merger. In the event of
bankruptcy, the provisions of applicable law will apply.
11. Corporate Privacy Officer. To
contact our Corporate Privacy Officer when indicated by this Policy
or to address questions regarding TPUSA's privacy practices, please
e-mail: Privacyofficer@teleperformance.com Letters may be sent to:
Teleperformance, 1991 South 4650 West, Salt Lake City, UT,
Version 1.0; Last Revised 14/04/09