Privacy Policy
GO LUXE respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does GO LUXE 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 GO LUXE 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) and from Switzerland to 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). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, GO LUXE adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).
SCOPE
This Safe Harbor Privacy Policy Statement (the “Policy”) applies to all personal information received by GO LUXE in the United States from the EEA and from Switzerland, 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 under the instructions of, and solely for, GO LUXE or to which GO LUXE discloses personal information for use on GO LUXE behalf.
“GO LUXE” means SMART LIVING, LLC, SMART LIVING LIMOUSINE OR SMART LIVING SPRINTER (d.b.a. GO LUXE), 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 GO LUXE 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, GO LUXE 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 GO LUXE 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 GO LUXE discloses that information, the choices and means, if any, MTC Limousine offers individuals for limiting the use and disclosure of personal information about them, and how to contact GO LUXE. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to GO LUXE or as soon as practicable thereafter, and in any event before GO LUXE uses or discloses the information for a purpose other than that for which it was originally collected.
Where GO LUXE 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: GO LUXE 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, GO LUXE 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.
GO LUXE will provide individuals with reasonable mechanisms to exercise their choices.
RESERVATIONS: If you make reservations or purchase a product or service from us, we request certain personally identifiable information from you at the time of booking. You must provide contact information (such as name, email, and address) and financial information (such as credit card number, expiration date).
We use this information for billing purposes and to process your reservations. If we have trouble confirming your reservations, we will use this information to contact you.
DATA INTEGRITY: GO LUXE will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. GO LUXE will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: GO LUXE 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), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where GO LUXE has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, GO LUXE will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, GO LUXE will grant individuals reasonable access to personal information that it holds about them. In addition, GO LUXE will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: GO LUXE has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorized GO LUXE personnel are provided access to personally identifiable information and these employees have agreed to ensure confidentiality of this information. GO LUXE’s policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. www.mtclimousine.com is using a 256-bit SSL certificate from Trustwave. This SSL Certificate provides encryption of personal information transmitted over the Internet securely.
ENFORCEMENT: GO LUXE will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that GO LUXE 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 the GO LUXE Privacy Office at the address given below. GO LUXE 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 GO LUXE and the complainant, GO LUXE 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 all personal information received by GO LUXE from UNITED STATES, GO LUXE has agreed and to cooperate with the UNITED STATES FDPIC;
2. for disputes involving employment-related personal information received by GO LUXE from the EEA, GO LUXE has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
3. for disputes involving all other personal information received by GO LUXE from the EEA, MTC Limousine has agreed to Privacy Trust dispute resolution. Individuals who submit a question or concern to GO LUXE and who do not receive acknowledgment from GO LUXE of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the Privacy Trust Safe Harbor Dispute Resolution Program on the Internet, by mail or by fax. Inquiries by mail or fax should identify GO LUXE as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether Privacy Trust may share the details of the inquiry with GO LUXE. Privacy Trust will act as a liaison to GO LUXE to resolve these disputes.
b. Mail: GO LUXE | 1728 S. CATALINA AVE. #2 | REDONDO BEACH, CA 90027
For information about Privacy Trust or the operation of Privacy Trust’s dispute resolution process or request this information from Privacy Trust by mail or fax using the contact information listed above. The Privacy Trust dispute resolution process shall be conducted in English.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by GO LUXE 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.
INTERNET PRIVACY
GO LUXE sees the Internet and the use of other technology as valuable tools to communicate and interact with consumers, employees, business partners, and others. GO LUXE recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy Statement (the “IPP”) governing the treatment of personal information collected through web sites that it operates.
CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to GO LUXE by mail to:
GO LUXE
1728 S. CATALINA AVE
SUITE 2
REDONDO BEACH, CA 90027
Or by e-mail to [email protected]
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 GO LUXE web page (www.goluxe.limo) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.
EFFECTIVE DATE: November 15, 2018