Bartech Group

PRIVACY POLICY

The Bartech Group, Inc. ("Bartech") has established a comprehensive privacy program designed to help us respect and protect your data privacy rights. This statement includes both Bartech's Website Privacy Statement and Bartech's European Union – U.S. Safe Harbor Privacy Policy Statement.

  1. Our Websites. Bartech respects the privacy of visitors to its websites. This privacy policy applies only to the operation of websites that directly link to this policy when you click on "privacy statement" in the website footer.
  2. U.S. Safe Harbor. For personal information of employees, suppliers and customers that Bartech receives from the European Economic Area, Bartech has committed to handling such personal information in accordance with the Safe Harbor Principles.

DEFINITIONS

"Personal Information" or "Information" means information that information or set of information that is recorded in any form; is about, or pertains to a specific individual; and can be linked to that individual. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-pubic Personal Information.

"Sensitive Personal Information" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual's health.

PRINCIPLES

Notice

Bartech shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of third parties to which Bartech discloses or may disclose that Information. Bartech shall provide the individual with the choice and means 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 Bartech, or as soon as practicable thereafter, and in any event before Bartech uses or discloses the information for a purpose other than for which it was originally collected.

Choice

Bartech will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) 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, Bartech will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Onward Transfers

Prior to disclosing Personal Information to a third party, Bartech shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure.

Data Security

Bartech shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Bartech has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Bartech cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity

Bartech shall only process Personal Information in a way that is compatible with and relevant for the purposes for which it was collected or authorized by the individual. To the extent necessary for those purposes, Bartech shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access

Bartech shall allow an individual access to their Personal Information and allow the individual 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 of persons other than the individual would be violated.

Enforcement

Bartech uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using the EU Data Protection Authorities as a third party resolution provider.

Amendments

This Privacy Policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on our website(s).

Information Subject to Other Policies

Bartech is committed to following the Principles for all Personal Information. However, certain information is subject to policies of Bartech that may differ in some respects from the general policies set forth in this Privacy Policy.

Contact Information

Questions or comments concerning this Policy should be directed to Bartech via mail or email as follows:

The Bartech Group, Inc.
Attn: General Counsel
17199 N. Laurel Park Drive, Suite 224
Livonia, MI 48152
ahorton@bartechgroup.com

Originally Posted: October 9, 2009