Privacy

Intrepid Learning Solutions recognizes that privacy is very important to our customers, and we pledge to protect the security and privacy of any personal information that customers provide to us. This includes customer’s names, addresses, telephone numbers, email addresses and any information that can be linked to an individual. Not only does Intrepid strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that Intrepid follows with respect to transfers of personal information from the European Union (EU) to the United States.

SAFE HARBOR

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 U.S. companies to satisfy the EU law requirement that personal information transferred from the EU to the United States be adequately protected. Consistent with its pledge to protect personal privacy, Intrepid adheres to the Safe Harbor Principles.

SCOPE

This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by Intrepid in the United States from the EU, in any format including electronic, paper or verbal.

DEFINITIONS

The following definitions shall apply throughout this Policy:

“Agent” means any third party that uses personal information provided to Intrepid to perform tasks on behalf of and under the instructions of Intrepid.

“Intrepid” means Intrepid Learning Solutions, its successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of Intrepid to identify an individual. Personal information does not include information that is encoded, anonymized, aggregated or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Intrepid will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy are based on the Safe Harbor Principles.

NOTICE: When Intrepid collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which Intrepid discloses that information, and the choices and means, if any, that Intrepid 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 Intrepid, or as soon as practicable thereafter, and in any event before Intrepid uses the information for a purpose other than that for which it was originally collected.

If Intrepid receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such personal information relates.

CHOICE: Intrepid will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, Intrepid will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Intrepid will provide individuals with reasonable methods to exercise their choices.

DATA INTEGRITY: Intrepid will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Intrepid will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: Intrepid will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If Intrepid has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Intrepid will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Intrepid will grant individuals reasonable access to personal information that it holds about them, and Intrepid will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: Intrepid will take reasonable precautions to protect personal information in its possession from loss, misuse and
Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by (your business name), please visit the BBB EU SAFE HARBOR unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Intrepid will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Intrepid determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Intrepid Privacy Office at the address given below. Intrepid 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 Intrepid and the complainant, Intrepid has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.

Intrepid Learning Solutions has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the Intrepid Privacy Office by mail or e-mail as follows:

Intrepid Privacy Office
411 1st ave S
Seattle, WA
98104

Email: privacyofficer@Intrepidls.com

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Intrepid will provide appropriate public notice about such amendments.

EFFECTIVE DATE: December 27, 2011