TeleTech Holdings, Inc. and its subsidiaries and affiliates (together, “TeleTech”) believe in protecting the privacy of personal information of our employees, shareholders, clients and their customers, vendors, business partners and visitors to our various websites. TeleTech endeavors to collect, use and store information for and about all of these groups in a manner consistent with the applicable and enforceable laws of the various countries in which TeleTech operates and in which these groups and their constituents reside. To this end, we have adopted a series of policies designed to protect that information and to inform those about whom we collect and handle personal information about our policies for protecting that information.
TeleTech expects employees, independent contractors, vendors and other users of systems and documents that may contain personal information to: (1) protect such personal information from unauthorized disclosure or use; and (2) destroy or delete such personal information when no longer required for the purpose intended or by law, whichever is longer.
Further, TeleTech expects each employee, independent contractor, vendor or other user of personal information to apply appropriate measures to protect personal information where collected, used or stored in accordance with the applicable and enforceable laws of those countries in which TeleTech is operating. As global laws and ethical concerns of privacy are constantly evolving, TeleTech will continue to adopt reasonable policies and information security measures to meet these evolving standards.
1. Non-Personal and Aggregated Information Collected Automatically. When you visit our Site, we log general data, such as your domain name (e.g., google.com, TeleTech.com), the name of the Web page from which you entered our Site, which pages you visit on our Site, and how much time you spend on each page. We use this information to continually monitor and improve our Site and for internal analysis. In particular, we use IP addresses to analyze trends, administer the Site, track user's movement, and gather information for aggregate use.
2. Personal Information That You Choose to Submit. As a visitor to our Site, you may choose to use the Site to send us personal information (e.g., your name, mailing address, telephone number, e-mail address), for example, when you send a question via the Site, register for a special service, submit your resume through our Site. Anytime you submit personal information for a specific purpose using the Site, your information is used for that purpose only, unless you consent otherwise or as required by law. When you submit personal information to TeleTech on this Site, you understand and agree that this information may be transferred across national boundaries and may be stored and processed in another country, which may not provide privacy protections similar to those your country provides.
We do not send unsolicited e-mail to you or other visitors to our Site. We may use e-mail to respond to e-mail messages from you, where necessary, to confirm information received online from you and to engage in other communication that you have authorized or that we have determined necessary to more effectively service you and our customers.
In many cases, you choose the amount of information you supply (e.g., when sending us information through the Site, you may choose to include only an e-mail address - not a telephone number or mailing address - for replies).
The term "cookie" refers to files that are transferred from a website to your computer's hard drive. The purpose of cookies is to enable us to track your activities on our Site. Cookies help us remember who you are. They work in the same fashion as the clerk in a store you visit on a regular basis. The store clerk may not necessarily know your name, but he or she recognizes that you have been in the store before and may remember what you usually purchase while you are in the store. Cookies permit us to gain the same kind of information about you and enable us to provide you with more efficient and personalized service. For example, for sites that require registration, a cookie file can be stored on your computer enabling you to skip the registration process on subsequent visits. Cookies are also frequently used to track the progression of a customer engaged in an online purchase to ensure that the transactional information remains intact.
Some (usually newer) versions of Web browsers allow you to decide whether or not to accept cookie files and some programs notify you when a website is about to deposit a cookie file on your hard drive. If you decide not to accept cookies, you may not be able to successfully navigate some portions of a website.
We may share non-personal, aggregated information with our customers, partners, and advertisers. Aggregated information is not linked to any personal information that can identify an individual person.
Unless we have your permission or are required by law, we only share the personal information you provide through our Site with TeleTech affiliates and/or business partners that are acting on our behalf. TeleTech reserves the right to disclose customer information to the extent authorized law. We make every reasonable effort to ensure that such TeleTech affiliates and business partners, including those in the U.S. and any other countries, protect your personal information consistent with this Policy.
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect through the Site. However, please be advised that TeleTech cannot guarantee and has no control over the public or third party network through which you send your personal information to TeleTech's Site.
We do not collect or maintain information at our Site from those we actually know are under 13, and no part of our Site is intended for anyone under 13 years of age. By entering this Site, users represent that they are 13 years of age or older.
This Site provides hyperlinks, which are highlighted words or pictures within a hypertext document that, when clicked, take you to another place within the document, to another document altogether, or to other websites not controlled by TeleTech. These hyper-linked websites may contain privacy provisions that are different from those provided herein and may also be web sites that are provided by, or under the control of clients of TeleTech. TeleTech is not responsible for the collection, use or disclosure of information collected through these websites, and TeleTech expressly disclaims any and all liability related to such collection, use, or disclosure.
The European Commission’s “Data Protection Directive” prohibits companies from transferring, storing or using personal information about residents of European Union (“EU”) member countries outside the EU without first adopting certain safeguards to prevent unauthorized use or access of such information.
Given that the United States and the EU member countries have adopted different approaches to safeguarding personal information, the EU and the United States Department of Commerce in July 2000 adopted a “safe harbor” framework that allows US companies to transfer, store or use personal information about residents of EU member countries while at the same time meeting the “adequacy standard” of the Data Protection Directive.
Under the safe harbor framework, US companies meeting the safe harbor criteria are considered by EU member countries and organizations within those countries as meeting the adequacy standard of the Data Protection Directive.
This Policy applies to all personal information - for or about individuals covered by the Data Protection Directive - we handle (except as noted below), including on-line, off-line, and manually processed data. For purposes of this statement, "personal information" means information that:
It does not include personal information that pertains to a specific individual, but from which that individual could not reasonably be identified
Notice and Choice
To the extent permitted by the Safe Harbor Agreement, we reserve the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved. Where we collect personal information directly from individuals in the E.U., we inform them about the types of personal information we collect from them, the purposes for which we collect and use it, and the types of non-agent third parties to which we disclose that information. We also inform those individuals about the choices and means, if any, we offer individuals for limiting the use or disclosure of their information.
Disclosures and Transfers
TeleTech will not disclose an individual's personal information to third parties, except when one or more of the following conditions is true:
Permitted transfers of information, either to third parties or within TeleTech, include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the personal information originated.
TeleTech takes reasonable steps to protect your personal information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of personal information, either for its own purposes or on behalf of our clients, TeleTech has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal information we process. However, we cannot guarantee the security of personal information on or transmitted via the Internet.
We process personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
Access and Correction
If an individual becomes aware that personal information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her personal information, the individual may contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete personal information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying personal information, such as name, address, birth date, and social security number. We may request additional identifying personal information as a security precaution. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.
TeleTech utilizes the self-assessment approach to assure its compliance with our privacy statement. TeleTech periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. We encourage interested persons to raise any concerns with us using the contact information below. We 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. With respect to any complaints relating to this Policy that cannot be resolved through our internal processes, we have agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Principles. If we or such authorities determine that we did not comply with this Policy, we will take appropriate steps to address any adverse effects and to promote future compliance. Any person who we determine is in violation of our privacy policies will be subject to disciplinary process. This Policy may be changed from time to time, consistent with the requirements of the Safe Harbor Agreement. We will post any revised Policy on this Site, or a similar Site that replaces this Site. We are committed to following the Principles for all personal information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of the firm that may differ in some respects from the general policies set forth in this statement: If a complaint is not satisfactorily addressed by TeleTech within a reasonable time frame, you may contact the Federal Trade Commission at www.ftc.gov/ftc/complaint.htm, or via phone at 202-382-4357. EFFECTIVE DATE: June 30, 2007 Compliance Department TeleTech Holdings, Inc.
Enforcement and Dispute Resolution
Privacy Statement Changes
Information Subject to Other Policies
TeleTech Privacy Contacts
9197 South Peoria Street
Englewood, Colorado 80112
TeleTech utilizes the self-assessment approach to assure its compliance with our privacy statement. TeleTech periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. We encourage interested persons to raise any concerns with us using the contact information below. We 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.
With respect to any complaints relating to this Policy that cannot be resolved through our internal processes, we have agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Principles. If we or such authorities determine that we did not comply with this Policy, we will take appropriate steps to address any adverse effects and to promote future compliance.
Any person who we determine is in violation of our privacy policies will be subject to disciplinary process.
This Policy may be changed from time to time, consistent with the requirements of the Safe Harbor Agreement. We will post any revised Policy on this Site, or a similar Site that replaces this Site.
We are committed to following the Principles for all personal information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of the firm that may differ in some respects from the general policies set forth in this statement:
If a complaint is not satisfactorily addressed by TeleTech within a reasonable time frame, you may contact the Federal Trade Commission at www.ftc.gov/ftc/complaint.htm, or via phone at 202-382-4357.
EFFECTIVE DATE: June 30, 2007
TeleTech Holdings, Inc.