Privacy Policy

Overview
EasyLink Services International Corporation (EasyLink or the Company) is a global provider of value-added services that facilitate the electronic exchange of documents and information between enterprises, their trading communities and their customers.  We recognize the importance of protecting the privacy of all information provided to us and to our clients through the use of our services and related websites.  This privacy policy is designed to inform our customers and others who visit our website about the manner in which we collect and use the personal information we receive from our customers and online from our website users.  If you visit our website and you elect to register for our services or provide us with personal information, you authorize us to use such information as set forth in this policy.

The Information EasyLink Collects
When you visit EasyLink’s website, you may provide us with two categories of information: (1) Personal information you choose to disclose to us on your behalf, and (2) Website use information that we collect on an aggregate basis as visitors browse our website. You may also provide us with additional information required for us to provide the services that you intend to purchase from EasyLink. Only personal information that is relevant to the requested service will be collected and we will verify such data to ensure it is accurate, complete and reliable. This may include: full name; company name; postal address; email address and telephone number. If you purchase our services, we may ask for your credit card number and other data to process your credit request. 

EasyLink may also collect personal information during our new hire applicant process that will be used solely to evaluate you as a candidate for employment. Job applicants may be requested to provide information such as educational background, employment experience and job interest.  We may also collect demographic information, such as your age, gender, interests and preferences.  Forms that may be necessary for you to complete will indicate whether information requested is mandatory or voluntary. 

Note that the above are only examples and is not encompassing of all data that may be collected. 

The Way We Use Information
EasyLink may use the personal information that you provide to us to notify you about important changes to our web site, our services or other offers we believe you will value. The Company may also use the information for research regarding the effectiveness of the website and the marketing, advertising and sales efforts of the Company, its trusted affiliates, independent contractors and business partners.  Visitors to our web site are not required to register or purchase our services to use our web site.

U.S.–EU & U.S.-Swiss Safe Harbor
The U.S. Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (FAQs) ("the U.S.-EU Safe Harbor Framework") to enable U.S. companies to satisfy European Union (EU) law requirements for adequate protection of personal information transferred from the EU to the United States. The U.S. Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles and frequently asked questions (FAQs) (“the U.S.-Swiss Safe Harbor Framework”) to enable U.S. companies to satisfy Swiss law requirements for adequate protection of personal information transferred from Switzerland to the United States.

This privacy policy is in accordance with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework and we are registered with the U.S. Department of Commerce's Safe Harbor Program. To learn more about the Safe Harbor program and to view EasyLink’s certification, please visit http://export.gov/safeharbor/.

Privacy Protection Principles
EasyLink has established seven interrelated privacy protection principles that form the basis of its privacy policy.  These principles have been established based on the principles advanced by E.U. Directive 95/46/EC, and the US Safe Harbor Framework.

Principle 1 – Notice

Through publication of this Privacy Policy, EasyLink is making available to individuals a clear, conspicuous, and accurate statement of its privacy practices. This policy applies to the Personal Information the Company collects about individuals and addresses the purposes for which it collects and uses Personal Information.  Throughout this policy EasyLink discloses its practices regarding the privacy principles noted below.

Principle 2 - Choice

The option to opt-out of collection, use, and disclosure of Personal Information is provided to all customers.  EasyLink ensures that proper processes exist to collect, retain and respect the individual’s preferences and to respond promptly to requests from individuals.

Principle 3 - Onward Transfer

Except as described in this policy, we won’t share your personal information with third parties without your consent, and then only with those third parties who share the Company’s commitment to protecting your personal information.

Principle 4 - Security

EasyLink will take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.

Principle 5 - Data Integrity

EasyLink will only collect the personal information needed for specific, identified purposes, and will not use it for other purposes without obtaining your consent.

Principle 6 - Access

EasyLink will provide a mechanism for all individuals to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights or privacy of persons other than the individual would be violated.

Principle 7 - Enforcement

EasyLink uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate and in conformity with the Principles.

Use of Cookies
Cookies are tiny text documents a web server can store temporarily with your web browser.  Cookies are useful for having your computer remember specific information from a particular web site's server to be reloaded the next time you surf that server's web site. Cookies could help us gather feedback on our web site to better serve our customers.

You may elect to be notified each time a web site's server asks permission to store a cookie by amending certain settings in your web browser so that you are able to refuse a cookie when it is being offered.

EasyLink use cookies primarily to learn about how visitors use our web site by analyzing usage patterns. We do not use information collected from cookies to profile individual visitor behavior.

Disclosure of Your Information
EasyLink may disclose information collected from users to trusted affiliates, independent contractors and business partners who will use the information to provide and enhance our services. However, we have committed to restrict their access as needed to provide their services to us or to you.  In addition, EasyLink will exercise due care in ensuring that the third party subscribes to all applicable privacy principles and fair information practices.  We may also disclose aggregate, anonymous data based on information collected from users to investors and potential partners.  Finally, we may also transfer information collected from users in connection with a sale of the Company’s business.

We have chosen a third party to process our credit card transactions in order to provide enhanced security, reliability and fraud protection mechanisms for your purchases. The credit card information that you choose to provide during your purchase is maintained in a secured folder on our server and is only accessible by EasyLink employees on a need to know basis. We do not store any sensitive credit card authentication data after authorization on our server.

Under certain situations, we may release your personal information if required by law, or if we believe the disclosure is necessary to abide by law or to protect our web site or users of our services, or to defend our property. We will only disclose the minimum information that we are required to disclose.

EasyLink Supports Children's Privacy
EasyLink takes children's privacy seriously. We do not knowingly collect personal information from children under the age of 13 through our websites.

If you are under 18 years of age, please do not submit any personal information through our websites without the express consent and participation of a parent or guardian.

Maintenance of Information
EasyLink is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure, such as encryption, passwords and physical security.  While we strive to protect your personal information, EasyLink cannot ensure or warrant that the personal information or private communications we collected will always remain private, and you do so at your own risk.

We maintain the personal information that you provide to us during the registration process on our servers from the time your account is active and for a period of time that is appropriate for the business transaction.

Updating your Personal Information/Questions
To request changes to your personally identifiable information, ask questions about our privacy practices, or issue a complaint, contact us at privacyinquiries@easylink.com or contact your designated administrator or postmaster.

Users may elect not to receive solicitations from EasyLink or from trusted affiliates, independent contractors and business partners by emailing optout@easylink.com.

Changes to This Policy
This Privacy Policy may be revised periodically, and this will be reflected by the effective date referenced below.  If we make material changes to this policy, we will post the changes on our web site located at http://www.easylink.com.  In general, we only use your personal information in the manner described in the Privacy Policy in effect when we received that personal information.  We encourage you to check our website frequently for updates.

 

Effective Date - July 28, 2011.