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BBG Communications
1658 Gailes Boulevard, San Diego, CA, 92154
Phone: 1.619.661.6661

Privacy Policy...continued

Safe Harbor Principles

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BBG has adopted the seven principles, present in both the EU and Swiss Frameworks, of notice, choice, onward transfer (transfer to third parties), access, security, data integrity and enforcement (the “Safe Harbor Principles”) with respect to End User name and credit card number information and human resource data to be transferred to the U.S. from operations in the EU and Switzerland ("Personal Information").

1. Notice: This Policy informs End Users about the purposes for which we collect and use Personal Information, how to contact us, the parties to which that information may be accessible, and the choices and means, if any, that BBG offers End Users for limiting the use and disclosure of such data.

2. Choice: BBG does not share End User names and/or credit card numbers with third parties, or use such data for a purpose other than the purpose for which it was originally collected, such as in connection with payment processing and authorization involving financial institutions and processing companies. For human resource data, BBG does not share such information with third parties or use such information for a purpose other than that for which the data was originally collected or subsequently authorized by the End User. As BBG does not share Personal Information with third parties, there is no need to offer End Users the opportunity to opt-out from having such data disclosed. Should the need ever arise, BBG will provide End Users with reasonable mechanisms to exercise their choice to opt-out from having such data disclosed.

3. Onward Transfer (Transfer to Third Parties): Prior to disclosing Personal Information to a third party (other than as disclosed in this Policy), should the need ever arise, BBG will apply the notice and choice principles detailed above. BBG will obtain assurances from third parties that they will safeguard the personal data consistently with this Policy or any other EU adequacy finding, or as an alternative, BBG may enter into a written agreement with such third party requiring that the third party provide at least the same level of personal data protection as is maintained by BBG.

4. Access: Upon request, BBG will grant End Users reasonable access to Personal Information that it holds about them and BBG will take reasonable steps to permit End Users to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.

5. Security: BBG will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

6. Data Integrity: BBG will use Personal Information only in ways that are compatible with the purpose for which it was collected or subsequently authorized by the End User. BBG will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete and current.

7. Enforcement: BBG will assure compliance with the Safe Harbor Principles by: (i) committing to investigate and attempt to resolve complaints regarding violations of its published privacy policy directly with the complainant, and in the events that the complaint cannot be resolved by BBG internally, the complainant may submit the matter to binding arbitration before the American Arbitration Association in San Diego, California; (ii) having an assessment procedure, whereby outside compliance audits (in connection with internal audits) will be conducted; and (iii) subjecting its employees who violate this Policy to discipline.


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