Thank you for visiting the iSKY Web site. This policy establishes how we will handle information we learn about you from your visit to our site. Please be assured that the privacy of our visitors is of utmost importance to us. We collect no personally identifiable information about you when you visit our site unless you choose to provide that information to us.
The specific practices outlined in this privacy statement apply to Web sites maintained by or on behalf of The Resource Group and its affiliates. Other organizations within The Resource Group may have slightly different practices, though the overarching commitment to your privacy will always be the same. You are encouraged to review the privacy policies of other organizations when visiting their Web sites. Some of our Web pages contain links to Web sites outside iSKY. Please be aware that when you follow a link to another site, you are then subject to the privacy policies of the new site.
Automatic Collections: For each HTTP (which is what your Web browser generates when you request a page or part of a page from a Web site) request received, we collect and store only the following information:
How the Information is used: We use the information that we collect to measure the number of visitors to the different areas of our sites, and to help us make our sites more useful to visitors. This includes analyzing these logs periodically to determine the traffic through our servers, the number of pages served, and the level of demand for pages and topics of interest.
How long is the Information retained: The logs may be preserved indefinitely and used at any time and in any way necessary to prevent security breaches and to ensure the integrity of the data on our servers.
Cookies: The Resource Group does not use "persistent cookies" or any other persistent tracking methods to collect personally identifiable information about visitors to its Web sites. Cookies are small files that Web servers place on a user's hard drive. They can serve several functions:
Personal Information via Forms: Some of our sites provide forms allowing visitors to submit search engine queries, questionnaires, feedback, or other information. Some of these forms may request personally identifiable information (e.g., name, address, e-mail address) for specific purposes, such as when the submitter is requesting a personal response, registering for a conference, or subscribing to a mailing list. All information submitted by visitors is voluntary.
We may store non-personally identifiable information we collect (such as search engine queries and anonymous survey responses) indefinitely to help us better understand and meet the needs of our visitors. We may share non-personally identifiable information with others, including the public, in aggregated form (for instance, in a list of our most popular search engine queries), in partial or edited form (such as in a report summarizing responses to a questionnaire), or verbatim (for example, in a complete listing of survey responses). Before collecting personally identifiable information, we will prominently disclose:
Consent to Information Collection /Sharing: Generally, we will not share any personally identifiable information you give us with any government agency, private organization, or the public, except with your consent or as required by law. By pressing the "submit" button, each visitor constitutes consent to use the information for purposes stated in this policy.
How e-mail is Handled: By sending us an electronic mail message (for example, an e-mail message containing information request), you may be sending us personally-identifying information. In these cases, we may retain the information as long as necessary to respond to your request or otherwise resolve the subject matter of your e-mail. Please be aware that email is not necessarily secure from interception or misdirection. For your own protection you may wish to communicate sensitive information using a method other than email.
Information Protection: We want to be very clear: regardless of the information being transmitted to any iSKY site, we will protect all such information consistent with applicable.
For site security purposes and to ensure that this service remains available to all users, this computer system employs software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage to the information on our Web sites. Unauthorized attempts to upload information or change information on this service are strictly prohibited and may be punishable under the Computer Fraud and Abuse Act of 1986.
Except for authorized law enforcement investigations, no other attempts are made to identify individual users or their usage habits. Raw data logs are used for no other purposes and are scheduled for regular destruction.
The Resource Group may share information received from its Web sites with other TRG affiliates. For example, if a breach of our IT security protections were to occur, the information collected by our servers and staff could be shared with appropriate law enforcement and Security officials.
Dispute Resolution: If for some reason you believe this site has not adhered to these principles; please notify the Director of Security and Compliance by e-mail at firstname.lastname@example.org. If our web pages are not fully in compliance with our stated policies, they will be corrected.
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, iSKY adheres to the Safe Harbor Principles.
iSKY has a Privacy Officer who is responsible for iSKY's compliance with and enforcement of this Policy. iSKY educates its employees concerning compliance with this Policy and has self-assessment procedures in place to assure compliance. iSKY's Privacy Officer 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. Relevant contact information is provided below.
This Policy applies to all Personal information received by iSKY in any format including electronic, paper or verbal. iSKY provides customized computer services designed to help companies manage their telecom facilities more effectively, increase profitability and reduce operational costs. iSKY collects and processes call detail records from customer telephone phone equipment, local and long distance carriers for the purpose of providing cost allocation, traffic analysis, fraud notification and other reports used for management of corporate telecom facilities. During this process, some or all the following information may be provided to iSKY by the customer based upon the scope of services to be rendered and local privacy laws:
Processed call information is made available to customers via a secured web interface or delivered directly to authorized customer recipients based upon customer instruction. iSKY does not own or control any of the information it processes on behalf of iSKY's customer. All such information is owned and controlled by iSKY's customer. In this capacity iSKY receives information transferred from the EU to the US merely as a processor on behalf of its customer and iSKY's customer remains the data controller.
iSKY will not sell or share this information with third parties unless required to do so by law. On a global basis, iSKY will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Policy.
All Personal information collected by iSKY will be used for legitimate business purposes consistent with this Policy.
Before starting any processing on behalf of iSKY's customer, iSKY will enter into a processing contract with the EU data controller responsible for the personal information pursuant to the applicable EU Member State Data Protection law. The processing contract ensures that the EU data controller (iSKY's customer) will be in compliance with the Member State Data Protection law. Any data processed by iSKY will not be further disclosed to third parties except where permitted or required by the processing contract, EU Safe Harbor or the applicable Member State Data Protection law. Any information which iSKY's customer (acting as the EU controller) identifies as sensitive will be treated accordingly.
The processing contract will also specify that the processing will be carried out with appropriate data security measures. iSKY has in place measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction.
The privacy principles in this Policy are based on the seven Safe Harbor Principles. NOTICE: Where iSKY collects Personal information directly from individuals, it will inform them about the purposes for which it collects and uses Personal information, the parties to which that information may be accessible, and the choices and means, if any, iSKY 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 iSKY, or as soon as practicable thereafter. iSKY may disclose Personal information if required to do so by law or to protect and defend the rights or property of iSKY.
Inquires or complaints regarding iSKY's adherence to this policy should be directed to the iSKY Privacy Officer identified in section 5 below.
As Personal information provided to or collected by iSKY is never disclosed to a non-agent third party, or used for a purpose other than the purpose for which it was originally collected and as iSKY's customer controls what level of Personal information is made available for iSKY processing, there is no need to offer individuals the opportunity to choose (opt-out) not to have their Personal information disclosed.
iSKY will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.
Although it is iSKY's intent to provide contracted services without use of Agents, certain circumstance may require the assistance of a reputable Agent as a subcontractor. In such circumstances iSKY will obtain assurances from its Agents that they will safeguard Personal information consistently with this Policy. Where iSKY has knowledge that an Agent is using or disclosing Personal information in a manner contrary to this Policy, iSKY will take reasonable steps to prevent or stop the use or disclosure. iSKY holds it Agents accountable for maintaining the trust our employees and customers place in the company. ACCESS: Upon request, iSKY will grant individuals reasonable access to Personal information that it holds about them. In addition, iSKY will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.
iSKY will take reasonable precautions to protect Personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. iSKY protects data in many ways. Physical security is designed to prevent unauthorized access to database equipment and hard copies of sensitive Personal information. Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access from remote locations. This protection includes the use of firewalls, restricted access and encryption technology. iSKY limits access to Personal information and data to those persons in iSKY's organization, or as agents of iSKY, that have a specific business purpose for maintaining and processing such Personal information and data. Individuals who have been granted access to Personal information are 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.
iSKY will use Personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. iSKY will take reasonable steps to ensure that Personal information is relevant to its intended use, accurate, complete and current.
iSKY will conduct internal 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 iSKY determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment
Any questions or concerns regarding the use or disclosure of Personal information should be directed to the iSKY Privacy Officer at the address given below. iSKY 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 iSKY and the complainant, iSKY agrees to participate in a dispute resolution procedure with The DMA Safe Harbor program, an independent, third party service to resolve the complaint. Submit written inquiries to:
iSKY 1700 Pennsylvania Avenue Suite 560 NW, Washington D.C., United States Or send via email to: email@example.com
The practices described in this Policy are current Personal data protection policies as of May 06, 2008. iSKY 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.