PRIVACY

Privacy

Chihade International, Inc.
Privacy Policy
11-4-13

• General

This Privacy and Security Policy (this “Privacy Policy”) explains how we collect, protect, use, and disclose the Personal Information (defined below), including, without limitation, any Personal Information gathered for and on behalf of Chihade, through any website operated by or on behalf of Chihade, including but not limited to, www.chihadeintl.com, together with any and all future websites that are operated by or on behalf of Chihade (together, the “Website”).

“Chihade”, “we” and “our” refer to Chihade International, Inc. and its operating subsidiaries and affiliates that adopt this Privacy Policy. By visiting the Website or otherwise disclosing Personal Information to Chihade, you are accepting the practices outlined in this Privacy Policy, which is subject to modification as described below. It is your responsibility to review this Privacy Policy frequently and remain informed about any changes to it, so we encourage you to visit this page often.

All Personal Information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. Chihade respects the privacy of our customers, our employees, job applicants, and other visitors to our Website who may choose to provide Personal Information. We recognize the need for appropriate protections and management of the Personal Information that you provide to us. This Privacy Policy will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.

• Consent

By using www.chihadeintl.com, or participating in any program or service managed by Chihade, or otherwise disclosing Personal Information to Chihade, you consent to the data collection and use practices described in this Privacy Policy. If you have questions about this Privacy Policy or the protection of your information, please contact the Privacy Officer at privacyofficer@chihadeintl.com.

SO THERE MAY BE NO DOUBT, BY SUBMITTING PERSONAL INFORMATION TO CHIHADE, AND/OR BY ACCESSING AND USING THE WEBSITE, YOU AGREE THAT CHIHADE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS AS PERMITTED OR REQUIRED BY LAW.

In addition to consenting to this Privacy Policy and the Terms and Conditions, including any relevant supplemental policies, you expressly consent to Chihade sharing the information that you have provided, as described herein. You agree that Chihade and those with whom it shares information (the "Recipients") may disclose and transfer your information worldwide, including in and outside the United States for any purpose relating to Chihade’s operations and programs.

• Types of Information We Collect

• Personal Information is any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to a Social Security Number and/or Identification Number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Personal Information shall include but is not limited to: name, home address, home zip code, home telephone number, mobile phone number, email address, Social Security Number and/or Identification
Number, financial information and employment related information such as may be found on resumes, applications, background verification information, or in employment references.

• Non-personal information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number.

• Sensitive data is information that can include but is not limited to, an individual’s gender, racial or ethnic origins, politics, religion, trade union membership, veteran status, physical or mental health, disabilities, sex life, sexual orientation, or criminal (or alleged criminal) activities, proceedings or convictions. We will never collect Sensitive Personal Information except to comply with Affirmative Action data requirements.

• Aggregate Information is information that is presented in summary or statistical form which does not contain data that would identify a specific individual.

• How We Collect Information

Chihade may collect Personal Information from its Website users in several ways:

• Use of the Website. When you visit a Website we may ask you for Personal Information so that we can provide you with the products, services, or information that you have requested. When you maintain a business account with Chihade and transact business with Chihade through the Website, we will ask you for information necessary to process and complete the transactions with us, including but not limited to, your name, shipping and billing addresses, e-mail address, and payment-related information.

• Cookies and Internet Monitoring Technologies. We use data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our Website.

• Internet Protocol (IP) Address. An Internet Protocol (IP) Address is associated with your computer's connection to the internet. Chihade may use your IP Address to help diagnose problems with Chihade’s server, to administer the Website and to maintain contact with you as you navigate through the Website. Your computer's IP address also may be used to provide you with information based upon your navigation through the Website. Chihade does not link IP addresses to any Personal Information.

• Aggregate Information – Aggregate Information is used to measure the visitors’ interest in, and use of, various areas of the Website and the various programs that Chihade administers. With this Aggregate Information, Chihade may undertake statistical and other summary analyses of the visitors' behaviors and characteristics. Although Chihade may share this Aggregate Information with third parties, none of this information will allow anyone to identify you, or to determine anything else personal about you.

• How We Use Personal Information.

We use your Personal Information to facilitate the services you request, evaluate prospective customers, suppliers and employees and, if we so elect, to open, maintain and terminate customer accounts, supplier arrangements, or employment relationships.

• Social Security Numbers/Identification Numbers. Chihade takes measures to maintain the confidentiality of your Social Security Number/Identification Number (hereinafter “SSN/IN”) to protect your SSN/IN from unlawful disclosure, and to limit access to your SSN/IN. Chihade will not make your SSN/IN available to the general public, print your SSN/IN on any card, require you to provide your SSN/IN to access any products or services, transmit your SSN/IN over the Internet unless the connection is secure or your SSN/IN has been encrypted, or requires the transmittal of your SSN/IN to access our Website without requiring additional authentication.

• Process Transactions with Customers and Suppliers. Chihade uses Personal Information to fulfill orders placed by customers, to order goods from suppliers, to respond to the requests of users of the Website, and generally to enrich the usefulness of the Website.  In addition, Chihade may use Personal Information, both on an identifiable and aggregate basis, in various analyses intended to help Chihade understand its customers and suppliers better. 

• Employee Personal Information. Chihade collects Personal Information from its employees and applicants (human resource data) in connection with administration of its Human Resources programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to Chihade facilities and computer networks, employee profiles, internal intranet employee directories, Human Resource recordkeeping, Affirmative Action data, and other employment related purposes.

It is the policy of Chihade to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are:

• To comply with county, state or federal agency requests;
• Inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below);
• Third parties with which Chihade has contractual agreements to assist in administration of company sponsored benefits.

• Verification of Employment. Prospective employers, financial institutions, and residential property managers routinely contact Chihade requesting information on a former or current employee's work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the Human Resources Department or Payroll Department. For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee's signed authorization to release information. The form will be returned directly to the requesting party and filed as part of the Human Resources or Payroll Department’s confidential records.

• Medical Information. Chihade only utilizes information related to the company sponsored healthcare plan on a “need to know” basis for administration of the healthcare plan.

• Sharing or Disclosure of Personal Information.

Chihade may share Personal Information with third parties as described below.

• Third Party Service Providers. We depend upon third parties and independent contractors (collectively “Service Providers”) to provide services in connection with our business operations.  We may transmit your Personal Information to or allow access to such information by Service Providers who assist us in a variety of ways, including in hosting our business information and data, allowing information technology providers and maintenance services to provide and support information technology systems and services, processing orders and payments, shipping products, sending catalogs, performing surveys, conducting promotions, advertising and marketing, processing job applications, providing recruitment and background screening, and sending e-mails and newsletters.  Without limiting the foregoing, we may make certain of the pages associated with our Website available for employment opportunities or human resources. They usually will be captioned "Careers" or "Career Opportunities" or will have similar labels or captions clearly indicating the employment opportunity subject matter and such pages may be co-branded with Service Providers. We use good faith efforts with these Service Providers to require them to protect the privacy of Personal Information by implementing adequate security measures and by using the Personal Information only as authorized and directed by Chihade.  We do not permit such Service Providers to use Personal Information for direct marketing or any other purposes not authorized by Chihade. 

• Corporate Transaction. Chihade reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of Chihade or of any of the business or assets or shares of Chihade or a division thereof in order for a customer to continue to receive the same products and services from the third party.

• Required by Law. Chihade may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on Chihade or its affiliates or the Website; (2) protect, enforce and defend the rights, property or safety of Chihade, our employees and contractors, our users or others;  (3) act in urgent circumstances to protect the personal safety of users of Chihade, its Website or the public; and (4) enforce or apply our terms of use, credit terms, and other business agreements and arrangements. Without limiting the foregoing, we may use Personal Information in connection with the collection or enforcement of your obligations to us. We may also share Personal Information with other companies and organizations for fraud protection and credit risk reduction.

• Security of Personal Information.

We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.

We safeguard your Personal Information on the Internet by using industry-standard practices. Although "guaranteed security" does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all
applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your Personal Information.

Currently, our Website utilizes a variety of different security measures designed to protect Personal Information by users both inside and outside Chihade, including the use of encryption mechanisms, password protection, and other security measures to help prevent unauthorized access to your Personal Information. This helps maintain the confidentiality, privacy, and integrity of your transactions, and helps to protect your confidential information from loss, misuse, interception and hacking.

• Notification of a Security Breach

If Chihade or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that Chihade, or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address Chihade or the Recipient has for you, in the good faith discretion of Chihade or the Recipient. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

• Storage, Retention and Accuracy of Personal Information.

Chihade will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose remains valid after termination of our relationship with you. We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

• Access, Control and Update Information About You.

We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you can email us at privacyofficer@chihadeintl.com to update your contact information. You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us by sending us an email at privacyofficer@chihadeintl.com. To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.

• Links to Other Websites

You should be aware that this Privacy Policy does not apply to any other websites to which a link may be provided on the Website.  We cannot control and are not responsible for the actions of third parties operating such sites.  You should not take the existence of an affiliation with, or a link from, the Website to any such other website to mean that it has a privacy policy similar to this one.  You should review the privacy policy of any such website. Some third parties may choose to share their personal data with Chihade; that sharing is governed by that third party company’s privacy policy.

• International Transfer of Personal Information

Personal Information collected on the Website may be stored and processed in the United States or any other country in which Chihade or its affiliates, subsidiaries, agents, or Service Providers maintain facilities and/or infrastructure, and by using the Website, you consent to any such transfer of information outside of your country.  Unless applicable law requires different security and protections to be applied in any given relevant jurisdiction, we apply the same principles in using, handling and transmitting data as described in this Privacy Policy in all of our operations.

• Access by Children

Chihade adheres to the federal privacy protection standards as stated in the Children's Online Privacy Protection Act (“COPPA”). Our Website is not intended for use by children and we do not knowingly collect any Personal Information from children under the age of thirteen (13). If a child under the age of thirteen (13) provides us with Personal Information we will delete that information upon the request of a parent.

• Opt-Out Procedures

You may have the opportunity to elect to receive email and mobile communications from Chihade. Chihade will only email you or send you mobile alerts if you elect to receive them. If you elect to receive email and mobile communications, Chihade will send you occasional updates about new additions to the Website as well as special offers and promotions of which you can take advantage. If at any time you decide you would rather not receive these types of communications from Chihade, you can opt-out by (i) clicking the unsubscribe link at the bottom of any Chihade email, (ii) update the contact preferences for your account, (iii) for mobile marketing, you may opt-out by following the instructions provided in the text messages you receive, or (iv) contact the Privacy Officer at privacyofficer@chihadeintl.com.

• Your California Privacy Rights

Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship (1) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please email the Privacy Officer at privacyofficer@chihadeintl.com or write to us at:

Privacy Officer
Chihade International, Inc.
P. O. Box 451329
Atlanta, GA 31145

We will respond to such written requests within 30 days following receipt at the mailing address above. We reserve the right not to respond to requests submitted other than to the address specified above or otherwise exempted by law. Please note that we are required only to respond to each customer once per calendar year.

• Contact Information

You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another individual to assist in completing your requested task. We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records.

If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at: (404) 292-5033; by Facsimile at: (404) 297-8920; by email at: privacyofficer@chihadeintl.com; or by mail at Privacy Officer, Chihade International, Inc., P. O. Box 451329, Atlanta, Georgia, 31145. We will address your concern and attempt to resolve any problem.

• Changes to our Privacy Policy

This is our entire and exclusive Privacy Policy and it supersedes any earlier version.  We may change this Privacy Policy at any time by posting a new version of this Privacy Policy on the Website.  We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the Personal Information we collect.  Your continued use of the Website, or disclosure of Personal Information after the posting of any amended Privacy Policy, shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy are effective immediately after being posted by Chihade.

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