Elite Commercial Incentive Services
January 1, 2015
What Information Do We Collect About You?
You can visit our Website, read materials, and browse other company information without giving us any personally identifiable information. In order to provide users and customers with the most efficient and enhanced personalized service and attention, and to accommodate certain requests, we request information about you in certain circumstances and collect certain information automatically.
Information You Volunteer
We collect personally identifiable information that you volunteer to us (such as your name, e-mail address, home address, phone number, and/or similar information), when you use our services or request information about services, support or training. This is referred to as “Personal Information.”
Information Collected Automatically
You have the right to request deletion of your account information, subject to our need to keep appropriate archives for our business operations. We maintain archives of our web logs, databases, and other systems and information. It is possible some of this information may remain archived after we delete the information from its active database. We maintain archives for disaster recovery, legal and other non-marketing purposes.
What Do We Do With Collected Information?
We use information you provide to fulfill your requests and improve our Website and services. Your phone number may be used in the event that our customer service representatives need to contact you and cannot reach you by email. We may, from time to time, produce reports for affiliated parties and vendors containing anonymous, aggregated information about our users and customers, such as demographic, age and online usage information. This information allows us to provide content and information that is most relevant to our users. We do not include any Personal Information of our users in these reports.
We also use collected information to evaluate and administer our services, fulfill customer requests, respond to any future problems, such as difficulties in navigating our Website or accessing certain features, and to gauge user trends to determine what products and services are most popular with users. We may use your email address to send you email about items that we feel you should know about. This includes special promotional items that Elite endorses and changes in terms and conditions and the latest updates on the Website. When we send you emails that include a link to the Website, that link may contain an alphanumeric identifier that allows us to identify the person to whom we sent the message so that we can personalize our content for that individual.
Users who no longer wish to receive our email updates or other notifications may opt-out of receiving these communications by following the instructions contained in the applicable email.
How Do We Share Personal Information?
Personal Information is available to Elite and the technical agents, partners and consultants who make our Website and services available to you. Anonymous information is or may be available to our business partners. We share your Personal Information with third parties only as described below.
Elite and Its Agents
Website hosting firms, technical and database consultants, advertisers and processing partners may have access to Personal Information in the course of making our services available. All companies working for and with Elite will only use Personal Information in accordance with our instructions and are not permitted to sell your information to third parties or to use it except as authorized by us and you, or as permitted or required by law.
Foreign Affiliates and Third Party Service Providers
Our affiliates and third party service providers may be located outside of the United States. We require affiliates and third party service providers who receive your Personal Information from us to provide your Personal Information with a comparable level of protection. However, your Personal Information will also be subject to the laws of those jurisdictions.
What Information Do Parties Other than Elite Collect?
It is important to note that those entities may not follow the same privacy policies as Elite. For instance, if you click on an advertisement on scenechronize.com, you may be taken away to an entirely different site. These links can also be from advertisers, content providers and/or partners who may use Elite’s logo and/or style as a result of a co-branding agreement yet they may still not follow the same privacy policies as Elite.
We may, in accordance with applicable law, use or disclose any information without notice or consent for the following purposes: as needed to satisfy any law, regulation or legal request; to conduct investigations of consumer complaints or possible breaches of law; to protect the integrity of our Website and our property; to protect the safety of our customers or others; to fulfill your requests; or to cooperate in any legal investigation.
Your Web browser offers so-called “cookies” which, if you allow their use, store small amounts of data on your computer when you visit a website. A “web beacon” is an embedded image file that specifically helps us track whether you have viewed a specific piece of content. Cookies do not contain any Personal Information about you and therefore cannot be used to identify you personally. However, cookies assist us in tracking which of our features you like best and make it easier to use our Website. You have the ability to accept or decline cookies by modifying your browser. Our Website is viewable even if you disable the cookie function on your browser. However, if you disable cookies, some advanced and customized features or offerings will not be available to you. We also use “cookies” to remember information you gave us so you don’t have to re-enter it each time you visit the site.
Most browsers are initially set to accept “cookies”. If you’d prefer, you can set yours to refuse “cookies”. You will not be able to use our service if you turn off the “cookies” option.
How Can You Control Your Personal Information?
We believe that choice in how and when you are contacted is key to customer satisfaction. You may write to us and update your contact information or ask that we not share your personal contact information with third parties, at: Elite Commercial Incentive Services, 7510 W. Sunset Blvd., Suite 612, Los Angeles, CA 90046, Att: Support. You may also contact us via email at email@example.com.
We will take all legally required steps to implement your opt-out requests promptly; but you may still receive promotional information from us by mail for up to 60 days due to printing and mailing schedules, and up to 10 days for e-mail.
Security of Your Personal Information
Although we have implemented systems and procedures to secure the data maintained by us, security during Internet transmissions can never be assured. Our policy is to limit access to Personal Information to those Elite employees or agents with a specific need to access or retrieve this information. We store data on multiple service systems, in controlled environments. To maintain security, we conduct internal reviews of our security measures on a regular basis. Remember, however, that any Personal Information you post on the internet is available to anyone.
None of the information on the Website is intended for the use of children under 13, and Elite does not knowingly register any person or accept information from any person under the age of 13.
Changes in Corporate Structure
Visitors and Customers Outside the United States
Our Website and the servers that make this Website available worldwide are located in the United States. Any information you provide in subscribing to our Website or registering at our Website may be transferred to the United States.
Do Not Track Notice
Elite does not track its users and customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track signals. You should be aware that some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Your California Privacy Rights
Under California Civil Code §§ 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information Elite shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Commercial Incentive Services, 7510 W. Sunset Blvd., Suite 612, Los Angeles, CA 90046, Att: Support or, via email, firstname.lastname@example.org. In your request, please specify that you want a “Your Elite California Privacy Rights Notice”. Please allow at least 30 days for a response.
Elite Commercial Incentive Services
7510 W. Sunset Blvd., Suite 612
Los Angeles, CA 90046
We will process personal data that is transferred to us from the European Economic Area (“EEA”) in accordance with the safe harbor principles agreed between the United States Department of Commerce and the European Commission (“Safe Harbor Principles”). These principles enable United States companies to satisfy the European Union (“EU”) requirement set out in the EU Data Protection Directive that personal data transferred from the EEA to the United States be adequately protected.
Changes to Our Safe Harbor Policy
It is our policy to post any changes we make to our safe harbor policy on this website. If we make material changes to how we treat the personal data that falls within the scope of our safe harbor policy, we will notify you through a notice on our website home page.
The date the safe harbor policy was last revised is identified at the bottom of the page. You are responsible for ensuring we have an up-to-date, active and deliverable e-mail address for you, and for periodically visiting our website and this safe harbor policy to check for any changes.
“We,” “us,” “our” and similar words refer to Elite Services and its subsidiaries and affiliates.
“Data Protection Directive”: EU Directive 95/46/EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
“Agent”: any third-party data processor that processes personal data provided by us on our behalf and under its instructions.
“Personal Data”: any information or set of information that identifies or could be used to identify (together with other information) a living individual. Personal data does not include information that is anonymised or aggregated.
“Sensitive Personal Data”: any Personal Data that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information that concerns health or sex life, and information about criminal or administrative proceedings and sanctions.
If we collect Personal Data directly from individuals in the EU, we will inform them about the purposes for which we intend to process that Personal Data, the types of non-agent third parties, if any, to which we will disclose that Personal Data, and the choices and means, if any, that we offer individuals for limiting the use and disclosure of their Personal Data.
We will provide notice to individuals in clear and conspicuous language when individuals are first asked to provide Personal Data to us, or as soon as practicable thereafter. In any event, we will provide notice before we use the Personal Data for a purpose other than that for which it was originally collected.
If we receive Personal Data from our subsidiaries, affiliates or other entities in the EEA, we will use that information in accordance with the notices those entities provided to the individuals to whom that Personal Data relates and the choices made by those individuals.
We will provide individuals with the opportunity to opt out of any disclosure of their Personal Data to any non-agent third party or the use of that data for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
We will not disclose Sensitive Personal Data to a non-agent third party or use Sensitive Personal Data for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless we have received the individual’s affirmative and explicit consent (opt-in).
We will provide individuals with reasonable methods to exercise their choices.
Onward Transfer of Personal Data
We will obtain assurances from our Agents that they will safeguard Personal Data in accordance with this safe harbor policy.
Appropriate assurances include:
a contract between us and the Agent that requires the Agent to provide at least the same level of protection as is required by the Safe Harbor Principles;
the Agent being subject to the Data Protection Directive;
the Agent being established in a country that is subject to a finding of adequacy by the European Commission under Article 25(6) of Data Protection Directive; or
safe harbor certification of the Agent.
We will take reasonable precautions to protect Personal Data we create, maintain, use or disseminate from loss, misuse, unauthorized access, disclosure, alteration and destruction.
We will take special care to ensure the security of Sensitive Personal Data.
We will use Personal Data only for the purpose for which it was first collected or subsequently authorized by the individual or for other compatible purposes.
We will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete and current.
Access and Correction
Upon request, we will provide individuals with reasonable access to the Personal Data that we hold about them 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.
We will take reasonable steps to permit individuals to correct, amend or delete Personal Data related to them that is inaccurate or incomplete.
We will conduct compliance audits of its relevant privacy practices to verify compliance with this safe harbor policy.
Any employee of ours that we determine has acted in violation of this safe harbor policy will be subject to disciplinary action up to and including termination of employment.
Any questions or concerns regarding our use or disclosure of Personal Data should be addressed to us at the address given below.
We will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of Personal Data in accordance with the provisions of this safe harbor policy.
For complaints and disputes relating to organization human resources data, that cannot be resolved between Elite and the complainant, Elite has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland. The panel may be contacted at email@example.com and individual EU DPAs may be contacted directly via the information provided at http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm. The contact information for the Swiss FDPIC can be found at: http://www.edoeb.admin.ch/kontakt/index.html?lang=en.
For complaints and disputes relating to all other types of data, that cannot be resolved between us and the complainant, we have agreed to participate in the Better Business Bureau EU Safe Harbor Dispute Resolution Program dispute resolution procedures in the investigation and resolution of complaints to resolve disputes in accordance with the Safe Harbor Principles. If you wish to file a complaint, you should follow the procedures at http://www.bbb.org/council/eusafeharbor/bbb-eu-safe-harbor-dispute-resolution-program/how-to-file-a-complaint-with-bbb-eu-safe-harbor/.
Questions or comments regarding this safe harbor policy should be submitted by mail to:
Elite Commercial Incentive Services
7510 W. Sunset Blvd., Suite 612
Los Angeles, CA 90046
This safe harbor policy was last updated on January 1, 2015.