Privacy and Security Policy

This Privacy and Security Policy is provided for the benefit of existing customers of Safe Communications, Inc.  (“Safe Communications”) as well as other consumers and parties who seek information from or about Safe Communications and/or its website(s), particularly www.AnonymousTips.com.

1.                  OPENING STATEMENTS

1.1              Our Commitment to Privacy  
At Safe Communications, we respect the privacy and the confidentiality of our customers’ information, particularly our customers’ personally identifiable information.  We are committed to keeping confidential the personally identifiable information you share with us.  This Privacy and Security Policy explains how Safe Communications collects, uses, discloses and protects the information we obtain.

Provided you are not in breach of any of your obligations under this or any other Safe Communications’ agreement, Safe Communications will use commercially reasonable efforts to maintain your anonymity when you use the Service.

1.2              Acceptance of Privacy Risks

While Safe Communications strives to maintain the anonymity and privacy of your electronic communications sent to and through our systems and websites, the nature of the Internet and electronic communications precludes the ability to guarantee that your communications will always remain secure and anonymous.  All electronic communications through any system will be susceptible to human error, power failures, malevolent intent, unauthorized intrusions, and other circumstances beyond our control.  Safe Communications has implemented and continues to employ commercially reasonable measures to minimize these risks.  However, the risks cannot be eliminated altogether.  Consequently, by using our services,  you acknowledge your acceptance and understanding of these risks and agree that Safe Communications shall not be held liable for the failure of any of its security protocols or falling prey to one or more inherent risks in the delivery and storage of electronic communications. 

1.3              Applicability of Privacy and Security Policy                                                                                     Our Privacy and Security Policy applies to all individuals and entities from whom or for the benefit of whom we receive personally identifiable information (also commonly referred to as personally identifying information) (“PII”), whether the PII be collected through our corporate owned websites; traditional mailing and/or faxing channels; telephone or electronic communications; from some other medium; or from our clients.

2.                  PERSONAL INFORMATION COLLECTED AND HOW IT IS USED

2.1              Personally Identifiable Information is any information that would, by itself, identify you or tend to identify you as a particular individual or entity.  This personally identifiable information may include, but not be limited to, your name, your address, credit card number, bank account information, and/or personal identification number (such as a social security number or driver’s license number).

2.1.1        Personally identifiable information does not include any public information that is readily attainable through federal, state or local public record distribution channels. 

2.1.2        Personally identifiable information does not include any information that, by itself, could not identify you as a particular individual or entity.

2.1.3        Personally identifiable information also does not include raw data that becomes aggregated for statistical purposes and cannot, thereafter, be identified with you as a unique individual or entity.

2.1.4        Safe Communications does consider your Internet Protocol (“IP”) address to be PII and will treat it as such.

2.2              Information Collected          

2.2.1        Safe Communications collects information that is considered personally identifiable information and other information that, by itself, would not be considered personally identifiable information.

2.3              Collecting and Using Personal Information               

2.3.1        Safe Communications will explain how it intends to use your personally identifiable information either before it collects the information (such as in this Privacy and Security Policy) or contemporaneously with the solicitation of such information about you.  Exceptions may exist where the intended use is obvious to a reasonable person.

2.3.2        We will use the information collected only for the purposes explained to you.  Further, we limit the collection of personally identifiable information to only that information which is necessary for the purposes explained to you.

2.3.3        Unless we are required to do so by law, we shall not obtain your consent before collecting personal identifying information about you from parties other than Safe Communications.  Rather, Safe Communications shall presume that you have previously provided such consent to any such third party from whom Safe Communications obtains such information.

2.3.4        Safe Communications restricts the use of your personally identifiable information to Safe Communications’ personnel.

2.3.5        We shall not sell your personally identifiable information in the normal course of business operations.  Should the Website be sold, this paragraph shall not restrict the transfer of your personally identifiable information as part of the Website sold to a third party.

2.3.6        We may use the personally identifying information you provide in registering with Safe communications to let you know of additional products and services about which you might be interested.  Safe Communications may also share your personal information with other service providers and businesses that may wish to offer you additional products and services.  However, Safe Communications will not disclose any Content created by you.  Additionally, Safe Communications will not use or share your PII in any way that would compromise its commitment to maintain your anonymity according to the terms of this policy and its Terms of Use.

2.3.7        Again, you may “opt out” of the uses described in paragraph 2.3.5 by modifying your account settings.

2.4              Disclosing Personal Information                                                                                                     

2.4.1        General. Safe Communications may provide your personally identifiable information to other persons where (a) we have your consent; (b) we have obtained information about you from a third party (presuming that you have previously provided such consent to any such third party from whom Safe Communications obtains such information); (c) we are required or permitted to do so by law; (d) you use the Website and/or Website Service in violation of the Terms of Use or use them for purposes other than those for which they were specifically intended; and/or (e) the terms of this Privacy and Security Policy and/or Safe Communications’ Terms of Use otherwise permit and/or provide for such disclosure.

2.4.2        Strategic Partners.  Safe Communications may employ, engage or retain certain trusted third parties (“Strategic Partners”) to perform functions and/or provide services on its behalf.  Safe Communications will share personally identifiable information with these Strategic Partners only to the extent necessary to perform the functions and/or provide the services for which they have been employed, engaged or retained.  Safe Communications shall also secure contractual obligations from our Strategic Partners to maintain the privacy and security of the PII shared with them.

2.4.3        Business Transfers.  Safe Communications reserves the right to sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a sale of assets; a merger, acquisition, or reorganization; or, filing for bankruptcy. You will have the opportunity to opt out of any such transfer if the planned processing of your information by the purchaser differs materially from that set forth in this Privacy and Security Policy.

2.4.4        Legal Compliance.  Safe Communications may disclose any information about you and/or Content created by you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to: (1) comply with an order from a court of competent jurisdiction, regulatory agency, and/or other governmental authority; (2) respond to claims or legal process (including subpoenas); (3) to enforce the terms of this and other Safe Communications’ agreements as well as to protect the property and rights of Safe Communications, its strategic partners or other third parties; (4) to protect, in Safe Communications’ sole discretion, the public or any person from harm; (5) to prevent or stop any illegal, unethical, or legally actionable activity; and/or, generally, (6) to comply with the law.

2.4.5        Notice.              Unless restricted from doing so, Safe Communications will attempt to notify you before Safe Communications releases any of your PII or Content pursuant to (1) and (2) in paragraph 2.4.4.  In such cases, Safe Communications will also provide you with general information on how you may seek to block such a release of information and/or direct you to resources that can provide such general information.  The provision of such general information to you is not and should not be construed as providing you with legal advice.  Additionally, Safe Communications is under no other obligation to assist you in challenging or opposing a release of your information.

2.5              Non-Personally Identifiable Information

2.5.1    In addition to collecting personally identifiable information as previously described, Safe Communications also collects other non-personally identifiable information.

2.5.2    Non-personally identifiable information collected by Safe Communications may be utilized without restriction.

2.5.3    Although non-PII can be used in a number of ways, you can be assured that the use of the non-personally identifiable information cannot identify you as an individual or entity.

2.5.4    Because non-PII cannot be used to identify you, Safe Communications may in its discretion provide non-PII to other persons.

2.6.            Information Obtained From Use of Safe Communications’ Websites

2.6.1.      Cookies

2.6.1.1.            Cookies can be defined as bits of data stored on your computer that allow website(s) to identify your browser and session.

2.6.1.2.            Safe Communications presently does not utilize “Cookies”.

2.6.1.3.            Many of our strategic partners may use Cookies.  Safe Communications maintains no control over the use of Cookies by our strategic partners and third-party advertisers.  For information on how these third parties utilize Cookies collected, you should examine their respective privacy policies.

2.6.1.4.            Most web browser’s automatically accept and collect Cookies.  Depending upon your web browser’s security settings, you may have the ability to reject all cookies.

2.6.2.      IP Addresses

2.6.2.1.            Safe Communications maintains a log of your IP address when you access our corporately owned websites. This IP address by itself does not allow us to collect additional information about you.

2.6.2.2.            OTHER THAN YOUR IP ADDRESS, SAFE COMMUNICATIONS DOES NOT DIRECTLY COLLECT ANY PERSONAL INFORMATION ABOUT YOU UNLESS YOU VOLUNTARILY PROVIDE US WITH THIS INFORMATION.

2.7              Data Retention                                                                                                                           

2.7.1.      Safe Communications shall use commercially reasonable efforts to maintain storage of tips subject to the terms of this Privacy and Security Policy and Safe Communications’ Terms of Use.

2.7.2.      The length of time for which Safe Communications retains your PII and other information will vary depending on the nature of the services for which the information has been collected and the nature of the information.

2.7.3.      Although this period may extend beyond the end of your relationship with Safe Communications, it will be retained for only so long as necessary for Safe Communications to respond to any issues arising from your relationship with Safe Communications.

2.7.4.      When Safe Communications no longer needs or requires your personal information, Safe Communications will destroy, delete, erase or convert information to an anonymous form.

2.7.5.      Safe Communications may delete stored messages over ninety (90) days old. 

2.7.6.      Should your account be terminated, Safe Communications may immediately and permanently delete all messages, Content, and records of your account.

3.      CONSENT

3.1.            Safe Communications may obtain your personal information through a variety of sources.  For each source or method, the manner of consent may differ.

3.2.            In general, Safe Communications operates on an “Opt-out” basis.  That is, Safe Communications presumes that by accessing this website you have read this Privacy and Security Policy and Safe Communications’ Terms of Use. Moreover, by providing the personal information requested (both personally identifiable and non-personally identifiable), you have consented to its use by Safe Communications for the stated purposes.

3.3.            For these reasons, unless and until you expressly inform Safe Communications you do not wish your information to be used, Safe Communications shall presume it has your consent.

3.4.            Where Safe Communications obtains information about a consumer from its customers or other third parties, Safe Communications presumes that the consumer has previously provided appropriate consent to the party from whom Safe Communications obtains the information.  In any case, the consumer can be assured that this Privacy and Security Policy applies to any information obtained from a third party.

4.      ACCESS

4.1.            Subject to certain limitations imposed by applicable privacy laws, you may request that Safe Communications provide you with a copy of your personal information and/or information regarding how we have used that personal information.

4.2.            Any such requests for such information should be directed to our Privacy Officer at the contact information provided below.

4.3.            We will make every effort to respond to your request in a reasonable timeframe.

5.      SECURITY

5.1.            Safe Communications takes the issue of protecting your anonymity and personal information very seriously.  Safe Communications protects the information it obtains about you with appropriate, commercially reasonable safeguards and security measures consistent with standard information practices. These measures include commercially reasonable technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration, or destruction.

5.2.            For security purposes, Safe Communications does not disclose all of its security measures.  Be assured that Safe Communications does employ commercially reasonable industry standard measures to protect your information.

6.      DISCLAIMER AS TO THIRD-PARTY WEBSITES

Although our corporate owned websites may contain links to other third-party websites and/or may be advertised on such third-party websites, Safe Communications is not responsible for the privacy practices or the content of such websites and specifically disclaims any such responsibility.  Safe Communications does not monitor the privacy practices or content of these websites.  If you have any questions about the privacy practices of a website other than a Safe Communications owned website, you need to contact the Privacy Officer of the website about which you have a question.

7.      PRIVACY OF CHILDREN

We make it a practice not to knowingly obtain and/or retain information about individuals under the age of thirteen (13).  Indeed, no part of our Website or Website Services is directed to anyone under the age of thirteen (13).

8.      REVISIONS TO PRIVACY AND SECURITY POLICY

8.1.            Safe Communications reserves the right to revise, amend, or modify this Privacy and Security Policy, our Terms of Use, and other online policies and agreements at any time and in any manner. 

8.2.            Safe Communications shall provide notice of such changes by posting the revised policies to the applicable Safe Communications owned websites.  As we do not collect email addresses or other contact information from those sending Anonymous Tips, we cannot send direct notification of such changes by emails to those individuals.

8.3.            With respect to this Privacy and Security Policy, you should visit our website at www.AnonymousTips.com from time to time to review the then-current terms.  At any time, the current-posted policies govern and shall be binding.

For Additional Information or Questions, Contact Our Privacy Officer                                   Safe Communications has a designated Privacy Officer.  If you have additional questions or concerns regarding how Safe Communications is managing or using your personal information, please send your concerns in writing to our Privacy Officer by e-mail at Privacy@SafeCommunications.com.


 




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