and technology business worldwide, Palomino Computer Solutions
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 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 Palomino Computer Solutions Corporation and
its subsidiaries, and is effective as of October 1, 2008. 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, Palomino Computer Solutions
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 existing agreements.
Privacy Principles We will observe the privacy principles described
below of Notice, Choice/Fair Processing, Access, Security/Integrity,
Onward Transfer and Enforcement/Compliance in processing Personal
Notice 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.
Choice/Fair Processing 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
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
We will enable individuals to choose whether their Personal Data can
be disclosed to a third party for direct marketing purposes.
Access 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 will be accessible and processed only by (i) Palomino
Computer Solutions employees, suppliers, business partners and
others who require access for the performance of their obligations
to Palomino Computer Solutions; (ii) any person granted access by
the individual to whom Personal Data pertains; and (iii) those
otherwise authorized by law or court order.
Security/Integrity 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
Onward Transfer When we transfer Personal Data within Palomino
Computer Solutions 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.
Enforcement/Compliance 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 procedures
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
Palomino Computer Solutions Web Sites In addition to all other Personal Data handled by
Palomino Computer Solutions, this policy applies to Personal Data
collected through Palomino Computer Solutions 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 Palomino Computer Solutions, and as such, we are not
responsible for their content.
Updating the Policy Changes in legislation and/or our business activities
may require that this policy be updated from time to time.