Privacy Shield / Safe Harbor Policy

US Internet Corp. (hereinafter the “Company” or “USI”) respect individual privacy and value the confidence of their customers, employees, consumers, business partners and others. The Company strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which they do business, and pride themselves on upholding the highest ethical standards in their business practices. This Privacy Policy (the “Policy”) sets forth the privacy principles that the Company follows with respect to personal information transferred from the European Union (EU) or Switzerland to the United States.

EU-US Privacy Shield

The Company complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  US Internet Corp. has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

US-Swiss Safe Harbor

US Internet Corp complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland.  US Internet Corp has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern.  To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/swiss 

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for the Company or to which the Company discloses personal information for use on their behalf.

“USI/USIC” means US Internet Corp. a Minnesota based Corporation in the USA.

“Personal information” means any information or set of information that identifies or is used by or on behalf of the Company to identify an individual. Personal information does not include information that is encoded or anonymized, 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, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health. In addition, the Company will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

“The Company” means US Internet Corp.

PRIVACY POLICY

Your privacy is very important to us. We want to make your experience on the Internet as enjoyable and rewarding as possible, and we want you to use the Internet’s vast array of information, tools, and opportunities with complete confidence.

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how US Internet (“USI”) collects information from all end users of USI’s Internet services (the “Services”)-those who access some of our Services but do not have accounts (“Visitors”) as well as those who pay a monthly service fee to subscribe to the Service (“Members”)-what we do with the information we collect, and the choices Visitors and Members have concerning the collection and use of such information. USI requests that you read this Privacy Policy carefully.

 

Personal Information USI Collects and How It Is Used

Introduction

USI collects information in different ways from Visitors and Members who access the various parts of our Services and the network of Web sites accessible through our Service. We use this information primarily to provide a customized experience as you use our Services and, generally, do not share this information with third parties. However, we may disclose personal information collected if we have received your permission beforehand or in very special circumstances, such as when we believe that such disclosure is required by law or other special cases described below.

Registration

Members are asked to provide certain personal information when they sign up for our Services including name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process is used to manage each Member’s account (such as for billing purposes). This information is not shared with third parties, unless specifically stated otherwise or in special circumstances. However, in instances where USI and a partner jointly promote the Services, USI may provide the partner certain personal information, such as the name, address, and username of persons who subscribed to the Services as a result of the joint promotion for the sole purpose of allowing us and the partner to assess the results of the promotion. In this instance, personal information may not be used by the partner for any other purpose. USI may also generate non-identifying and aggregate profiles from personal information Members provide during registration (such as the total number, but not the names, of Members). As explained in more detail below, we may use this aggregated and non-identifying information to sell advertisements that appear on the Services.

USI Partners and Sponsors

Some USI products and services are offered to Visitors and Members in conjunction with a non-affiliated partner. To provide Visitors and Members some of these products and services, the partner may need to collect and maintain personal information. In these instances, you will be notified before any such data is collected or transferred and may decide not to use that particular service or feature.

Online Shopping

At some Web sites, you can purchase products and services or register to receive materials, such as a catalog or new product and service updates. In many cases, you may be asked to provide contact information, such as your name, address, email address, phone number, and credit/debit card information. If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient’s name, address, and phone number. USI has no control over the third parties’ use of any personal information you provide when placing such an order. Please exercise care when doing so.

Responses to Email Inquiries

When Visitors or Members send email inquiries to USI, the return email address is used to answer the email inquiry we receive. USI does not use the return email address for any other purpose and does not share the return email address with any third party.

Voluntary Customer Surveys

We may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of services we offer and how we provide them to you. Your personal information and responses will remain strictly confidential, even if the survey is conducted by a third party. Participation in our customer surveys is voluntary.

Special Cases

It is USI’s policy not to use or share the personal information about Visitors of Members in ways unrelated to the ones described above without also providing you an opportunity to opt out or otherwise prohibit such unrelated uses. However, USI may disclose personal information about Visitors or Members, or information regarding your use of the Services or Web sites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including: to satisfy laws, such as the Electronic Communications Privacy Act, regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Acceptable Use Policy or other user policies; to operate the Services properly; or to protect USI and our Members.

“Cookies” and How USI Uses Them

A “cookie” is a small data file that can be placed on your hard drive when you visit certain Web sites. USI may use cookies to collect, store, and sometimes track information for statistical purposes to improve the products and services we provide and to manage our telecommunications networks. These cookies do not enable third parties to access any of your customer information. Additionally, be aware that if you visit non-USI web sites where you are prompted to log in or that are customizable, you may be required to accept cookies.

Advertisers and partners may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.

USI’s Commitment to Children’s Privacy

Protecting children’s privacy is especially important to us. It is our policy to comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws. For information about tips, tools, age-appropriate or kid-friendly Web sites and how to report online trouble, please visit www.getnetwise.org USI recommends that children ask a parent for permission before sending personal information to USI, or to anyone else online.

Public Forums

Please remember that any information you may disclose in public areas of the Internet becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.

USI Commitment to Data Security

Services and Web sites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information.

CHOICE

The Company 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, the Company 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.

To limit the use and disclosure of their personal information, individuals may submit a written request to the contact information listed in the Dispute Resolution section below.

DATA INTEGRITY

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

ONWARD TRANSER

The Company will obtain written agreements from their agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is set forth in this Policy. Where the Company becomes aware that an agent is using or disclosing personal information in a manner contrary to this Policy, the Company will take reasonable steps to prevent or stop the use or disclosure.

USI also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements

US Internet’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, US Internet Corp. remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless US Internet proves that it is not responsible for the event giving rise to the damage.

ACCESS AND CORRECTION

Individuals have the right to obtain our confirmation of whether we maintain personal information relating to you.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also may correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their written query to the contact information listed below.  If requested to remove data, we will respond within a reasonable timeframe.

Your right to access your Personal Data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access.  If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.

SECURITY

The Company will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT

The Company will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that the Company determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.  US Internet Corp is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

DISPUTE RESOLUTION:

EU-US Privacy Shield

In compliance with the EU-US Privacy Shield Principles, US Internet Corp commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact US Internet Corp at:

US Internet Corp
Attention: Human Resources
12450 Wayzata Blvd. Suite 121
Minnetonka, MN 55305
P: 952.253.3200
F: 952.545.0302

US Internet Corp has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

US-Swiss Safe Harbor

In compliance with the US-Swiss Safe Harbor Principles, US Internet Corp commits to resolve complaints about your privacy and our collection or use of your personal information.  Swiss individuals with inquiries or complaints regarding this privacy policy should first contact US Internet Corp at:

US Internet Corp
Attention: Human Resources
12450 Wayzata Blvd. Suite 121
Minnetonka, MN 55305
P: 952.253.3200
F: 952.545.0302

US Internet Corp has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

CHANGES TO THIS PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the EU-US Data Shield Principles. A notice will be posted on the Company’s web page www.usinternet.com.

Last Modified: December 6, 2016