PRIVACY POLICY

Are you really reading this?  You must have a lot of time on your hands. We’re only kidding… sort of. ISS 24/7 respects individual privacy and values the confidence of its customers, employees, business partners and others. Not only does ISS 24/7 strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy Statement (the “Policy”) sets forth the privacy principles ISS 24/7 follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States, and from within the United States.

Safe Harbor

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Consistent with its commitment to protect personal privacy, ISS 24/7 adheres to the principles set forth in the U.S.-EU Safe Harbor.

We self-certify compliance with:
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Scope

This Safe Harbor Privacy Policy Statement (the “Policy”) applies to all personal information transmitted to ISS 24/7 in the United States from the EEA, in any format, including electronic, paper or verbal.

Definitions

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

“Agent” means any third party that collects or uses personal information while under the subscription of the ISS 24/7 service or to which ISS 24/7 discloses personal information for use on ISS 24/7’s behalf.

“ISS 24/7” means Instant Sales Solution, Inc. D/B/A ISS 24/7, its predecessors, successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of ISS 24/7 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, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, ISS 24/7 will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Privacy Principles

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

Notice: Where an ISS 24/7 Agent collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which ISS 24/7 discloses that information, the choices and means, if any. ISS 24/7 Agents are to offer individuals for limiting the use and disclosure of personal information about them, and how to contact ISS 24/7. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to ISS 24/7, or as soon as practicable thereafter, and in any event before ISS 24/7 uses or discloses the information for a purpose other than that for which it was originally collected.

Where ISS 24/7 receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

Choice: Agents 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, Agents 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.

ISS 24/7 will provide individuals with reasonable mechanisms to exercise their choices.

Data Integrity: ISS 24/7 will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. ISS 24/7 will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

Transfers to Agents: ISS 24/7 will obtain assurances from its 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 required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission. Where ISS 24/7 has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, ISS 24/7 will take reasonable steps to prevent or stop the use or disclosure.

Access and Correction: Upon request, ISS 24/7 will grant individuals reasonable access to personal information that it holds about them. In addition, ISS 24/7 will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

Security: ISS 24/7 will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement: ISS 24/7 will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that ISS 24/7 determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution: Any questions or concerns regarding the use or disclosure of personal information should be directed to ISS 24/7 at the address given below. ISS 24/7 will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between ISS 24/7 and the complainant, ISS 24/7 has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

1. For disputes involving personal information received by ISS 24/7 from the EEA, ISS 24/7 has agreed to cooperate with the Data Protection Authorities (DPAs) in the EEA and to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities.

2. For disputes involving employment-related personal information received by ISS 24/7 from the EU, ISS 24/7 has agreed to cooperate with the Data Protection Authorities (DPAs) in the EEA and to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities.

International Customers and Users

Please note ISS 24/7 complies with the U.S.-EU 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. ISS 24/7 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 our certification page, please visit this page.

Limitation on Application of Principles

Adherence by ISS 24/7 to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

Contact Information

Questions or comments regarding this Policy should be submitted to ISS 24/7 by mail to:

ISS 24/7

12411 NW 35th Street

Coral Springs, FL 33065 USA

Or by e-mail to ISS 24/7

Changes to this Safe Harbor Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the ISS 24/7 web page (www.iss247.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.

TERMS OF SERVICE FOR TEXT COMMUNICATIONS

Effective Date: January 1, 2011

The ISS 24/7 service operates on short code 69050, 33607, and 58154 in the USA. In the US, short codes are governed and administered by the Common Short Code Administration (CSCA). All service providers are required to comply with the directives of the Mobile Marketing Association and adhere to its Best Practices Policy. Please note that short codes may change in accordance with future requirements.

Text HELP to 69050, 33607 or 58154 for help.

Text STOP, END, QUIT, CANCEL, UNSUBSCRIBE, STOPALL to 69050, 33607 or 58154 to be removed from any Alert or marketing list and end subscription.

We only obtain the minimum amount of information we need to perform our services. At no time, will we allow personal information to be used for the promotion of unrelated services.

Alerts sent via SMS may not be delivered to you if your phone is not in range of a transmission site, or if sufficient network capacity is not available at a particular time. Even within a coverage area, factors beyond the control of your wireless carrier may interfere with message delivery, including the customer’s equipment, terrain, proximity to buildings, foliage, and weather. You acknowledge that urgent alerts may not be timely received and that your wireless carrier does not guarantee that alerts will be delivered.

If you subscribe to our SMS Services, you thereby agree to receive SMS Service messages at the address you provide for such purposes. Maximum messages will be no more than 4msgs/wk. Participation in our service is free of charge but “Message and Data Rates May Apply”. You may change your mind at any time by following the opt-out instructions above.

You represent that you are the owner or authorized user of the wireless device you use to sign up for the SMS Service, and that you are authorized to approve the applicable charges. www.iss247.com or our affiliates will never rent or sell your phone number to any third party, nor will we use your phone number to initiate a call or SMS message to you without your express or implied prior consent.

Data obtained from you in connection with this SMS service may include your cell phone number, your carrier’s name, and the date, time and content of your messages and other information that you may provide. We may use this information to contact you and to provide the services you request from us, and to otherwise operate, develop and improve the service.

Your wireless carrier and other service providers also collect data about your SMS usage, and their practices are governed by their own privacy policies. You acknowledge and agree that the SMS Service is provided via wireless systems to transmit communications over complex networks. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service.

In addition, we strictly prohibit any spamming activities. Any cell phone number included in a customer database must be an opt-in recipient and all customers must provide proof of such relationship if asked by either the recipient or by Instant Sales Solution, Inc. D/B/A ISS 24/7.

Message & Data Rates May Apply

ISS 24/7 operates on a Standard Rate short code which means that mobile users who send/receive text messages to and from the ISS 24/7 service will only be charged in accordance with the individual rate plan with their respective wireless service providers. We do not reverse-bill the recipient of the text messages. You must be 18 years or older or have permission from a parent/guardian to participate in any campaign. ISS 24/7 solely provides Alert & marketing text platform services for participating companies and takes no legal or any other responsibility for services and promotions offered or messages sent to their customers.

Wireless Service Providers

ISS 24/7 operates on the following wireless service providers. Please note that the supporting Wireless Service Providers may change in the future as new providers are added or existing providers no longer agree to support the service.

USA: AT&T, Alltel, Boost, Sprint, TMobile, U.S. Cellular, CellularOne, Verizon Wireless, Virgin Mobile, Cincinnati Bell, Cricket/Leap Wireless, ACG, Metro PCS, RCG and Tier 2/3.

Questions or need further help? Send your email to CustomerCare@www.iss247.com or call 954-514-8988.