In the course of conducting our information services and
technology business worldwide, The Fins Up! Foundation
collects and processes personally identifiable information of our Web site visitors. Maintaining the integrity and confidentiality
of Personal Data and handling it correctly is central to the way we conduct
our business activities. This policy describes how we handle Personal Data.
Personal Data is information that can be used directly or indirectly to
identify a living individual. Personal Data may include sensitive categories
of information, such as information that reveals racial or ethnic origin,
political opinions, religious beliefs, trade union membership, health or
sexual orientation (Sensitive Personal Data).
This policy applies to The Fins Up! Foundation, and is effective as of
January 1, 2004. All
employees will be required to abide by this policy.
This policy is designed to protect Personal Data under applicable law as it
is currently exists. However, The Fins Up! Foundation
realizes that this policy cannot address every potential issue and
circumstance. Therefore, we acknowledge that this policy is subject in all
respects to applicable local legal and regulatory requirements and existing
agreements and confirm that we will comply with such requirements and
We will observe the privacy principles described below of
Notice, Choice/Fair Processing, Access, Security/Integrity, Onward Transfer
and Enforcement/Compliance in processing Personal Data.
When we collect and process Personal Data about individuals,
we will make certain information available to those individuals on a
reasonable and timely basis. This information will include what Personal
Data is being collected, who is collecting it, how and for what purposes it
is being collected, how it is being used and to whom it will be disclosed.
We will process Personal Data only with consent or when such
processing is permitted by applicable law. If we need to process Sensitive
Personal Data, we will obtain explicit consent for such processing, unless
such processing is permitted by applicable law.
We will not process Personal Data in a manner incompatible with the purposes
for which it was originally collected unless later authorized by the
affected individuals or allowed by law; we will take reasonable steps to
ensure that such data is accurate, adequate, relevant and not excessive in
relation to such purposes; and we will not keep such data longer than is
necessary for such purposes.
We will enable individuals to choose whether their Personal Data can be
disclosed to a third party for direct marketing purposes.
We will allow individuals reasonable access to their Personal
Data to verify, correct or delete their data, where inaccurate. We will also
provide a means for individuals to exercise all other legal rights that they
may have in relation to their Personal Data.
Personal Data will be accessible and processed only by (i) The Fins Up! Foundation employees, suppliers, business partners and others
who require access for the performance of their obligations to The Fins Up! Foundation; (ii) any person granted access by the
individual to whom Personal Data pertains; and (iii) those otherwise
authorized by law or court order.
We will take reasonable security procedures through
appropriate technical and organizational measures to protect against
unauthorized or unlawful access or processing, disclosure, alteration,
destruction or accidental loss of Personal Data.
We will utilize reasonable means to keep Personal Data accurate, complete
and current in order to protect the quality and integrity of Personal Data,
however, we rely on individuals to provide all relevant information and to
advise us of any changes to their Personal Data to ensure that it remains
accurate, complete and current.
When we transfer Personal Data within The Fins Up!
Foundation or to third parties (including our suppliers and
business partners), we will observe the privacy principles of Notice and
Choice (described above), and we will require all the recipients of such
data to provide at least the same level of protection for such data as
specified by the standards stated in this policy.
We will follow internal processes for handling complaints
regarding our management of Personal Data.
We will demonstrate our compliance with this policy by:
publishing this policy conspicuously so that it is accessible to all
appointing and maintaining a Privacy Officer with responsibility for
developing and implementing a privacy program
implementing procedures to execute this policy in the conduct of our
business, including training our employees in the use of such procedures and
disciplining employees for failure to comply with this policy and its
at least annually, reviewing this policy to ensure that it continues to
comply with prevailing privacy standards, current applicable law and
regulations and existing agreements
The Fins Up! Foundation Web Sites
In addition to all other Personal Data handled by The Fins
Up! Foundation, this policy applies to Personal Data collected through
The Fins Up! Foundation Web sites.
As a convenience to our Web site visitors, we sometimes provide links to
other Web sites. These linked sites are not under the control of The Fins
Up! Foundation, and as such, we are not responsible for their
Updating the Policy
Changes in legislation and/or our business activities may
require that this policy be updated from time to time.