Adopted: April 24th, 2012
APX complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. APX has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view APX’s certification, please visit http://www.export.gov/safeharbor.
Notice: Information we collect and how we use it
APX collects and uses personal and other information in a number of ways.
Registration with APX
When you sign up for a particular service that may require registration, we ask you to provide personal contact information such as your name, address, telephone number and email address. This information may also include basic account information for billing or other purposes.
Information for Processing from Other Business Organizations
APX may receive information from other business organizations such as our clients for the purpose of providing services to these organizations. Some of this information may be non-public personal information or confidential account information. Generally, we process this information on their instructions and subject to confidentiality provisions.
Information Automatically Logged
A number of APX applications use web server logs and similar tools to help diagnose problems with the server, to administer the website, and to enhance security or authenticate users. Server logs are analyzed by a commercial tool to provide simple access demographics, including “New vs. Returning Visitors,” “Top Visitors,” “Top Geographic Regions,”, and other statistical reports.
When you send email or other communications to APX, we may retain and use those communications in order to process your inquiries, respond to your requests, and improve our services.
Other Purposes and Sharing
It is APX’s policy not to use or disclose confidential or non-public information received from clients or end-user customers except in connection with the provision and improvement of APX services. Such uses or disclosures may include, for example, those that are usual, appropriate, or acceptable to carry out the APX service for which the information was given or a transaction related thereto, to maintain accounts, to provide confirmations and statements, to provide access to data services, and for record keeping purposes. In addition to the uses and disclosures set forth above, APX may use information you provide or it otherwise receives for:
- auditing, research, and analysis in order to maintain, protect, and improve our services;
- ensuring the technical functioning of our network;
- satisfying any applicable law, regulation, legal process, or enforceable governmental request;
- detecting, preventing, or otherwise addressing fraud, security or technical issues; or
- protecting against harm to the rights, property, or safety of APX, its users or the public as required or permitted by law.
Sharing of Aggregated and Non-Personal Information
We may share with third parties certain pieces of aggregated, non-personal information. Such information does not identify you individually or compromise any aspect of confidential information or transactions.
International Users and Location of Data Processing
APX processes personal, confidential, and non-public information on our servers in the United States of America and in other countries where data protections may differ and in some cases be less adequate than those found, for example, in the European Union or Switzerland. In some cases, we may process such information on a server outside your own country. Individuals outside the United States who submit personally identifiable information via this website acknowledge and agree that the information submitted will be forwarded to the United States or other jurisdictions for processing in connection with the purposes for which it has been supplied.
Links to Other Websites
Our websites may contain (resource) links to other websites. APX is not responsible for the privacy practices or the content of such websites. Users linking to other websites are encouraged to verify the privacy practices of the other websites.
Choice: Options Concerning Information We Collect
Administrative and Marketing Communications: We Do Not Share with Third Parties for Their Marketing Purposes
It is the policy of APX not to disclose confidential or non-public information to third parties for their direct marketing purposes.
APX does not endorse or promote offers from third party advertisers and will not share your information with them.
Clients and end-user consumers consent to receiving administrative and related electronic communications related to our relationship.
Onward Transfer: Vendor and Supplier Information Sharing
APX may disclose information to third parties such as vendors and suppliers who may act as our agent and with third parties on whose behalf we are collecting such information where such sharing is required by our business relationship. Such sharing occurs subject to appropriate confidentiality obligations. We require our vendors and suppliers to agree to process such information based on our instructions and any other appropriate confidentiality and security measures.
Access: Your Right to Know and Correct the Information We Hold
APX strives to ensure that personal information is kept accurate and up to date. APX kindly requests its clients and end user customers to assist APX in complying with this obligation by informing APX of any changes to their personal information. Clients and end-user customers have the reasonable right to request details of the personal information that APX holds and to request the deletion or modification of any inaccurate personal information held by APX. Requests to access, modify, or delete such personal information should be sent in writing to the address indicated below.
Security: Our Efforts to Protect Information
APX takes reasonable precautions to protect personal, confidential, and non-public information. APX has established an information security program setting forth standards for maintaining administrative, technical and physical safeguards to govern information in our care, custody, or control.
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Despite our efforts, we cannot guarantee that information we process may not be accessed, disclosed, altered, or destroyed by breach of our security measures. In the event of a security incident, we will notify our clients or end-user customers in accordance with applicable law.
Questions and Enforcement
When we receive formal written complaints at this address, it is APX’s policy to contact the complaining user regarding his or her concerns.
APX will cooperate with relevant data protection authorities in the investigation and resolution of complaints brought under the Safe Harbor Principles where applicable.
You can contact APX through our website or as follows:
by telephone at (201) 748-7900 or in writing at:
Attn: General Counsel
31 W 34th Street, Suite 8005
New York, NY 10001