ELM Solutions Privacy Policy

ELM Solutions (“The Company”) has made the commitment to take all reasonable measures to protect your Personal Information and your privacy online. Please read the following Privacy Policy to understand how your Personal Information (as defined below) will be treated as you use our Passport® Collaboration Portal service, which includes, but is not limited to, the use of the wkelmsolutions.com website and the Passport Collaboration Portal website (collectively with all subpages thereto, the "Site"), their related services and software, software and services of third parties incorporated in the Site, associated media, printed materials, and electronic or "online" documentation, made available both now and/or in the future (collectively the "Services"). By accessing or using the Site or Services, you confirm that you have read, understood and agree to the terms of the The Company’s Privacy Policy, as outlined below.  If you do not agree to these terms, please do not access or use the Site or the Services.  Unless The Company has entered into a written agreement with you that expressly replaces or supplements this Privacy Policy, this Privacy Policy describes the privacy policies that apply to you while you are using the Services.

The Company has certified that it abides by the Safe Harbor privacy principles as set forth by the US Department of Commerce regarding the collection, storage, use, transfer and other processing of Personal Information transferred from the European Economic Area (“EEA”) or Switzerland to the United States.  The Company’s Safe Harbor Policy is available here.  The provisions of The Company’s Safe Harbor Policy – particularly as they relate to notice, choice, access to Personal Information, onward transfers, and data integrity, are incorporated herein and made a part of this Privacy Policy for all purposes.  The Company’s Safe Harbor certification can be found on the US Department of Commence Safe Harbor List.  For more information about the Safe Harbor principles, please visit www.export.gov/safeharbor.

Personal Information, Non-identifying Information, and ePacket Content

"Personal Information" means any information which is directly associated with an identified or identifiable individual, such as the name, e-mail address, physical address, or phone number. IP addresses are not considered Personal Information unless they are associated with a specific individual user. The Company will use Personal Information only in the manner described in this Privacy Policy and will not otherwise share Personal Information with any third party unless The Company has received prior consent for such use.

"Non-identifying Information" is any information that will not be linked to a specific person. The Company may use and share Non-identifying Information we collect from the Site or Services for our business purposes.

Persons who register at the Site and agree to our User Account Registration Agreement can access and use the Services. All information that you transmit by means of the Services is referred to as "Content" whether such information is Personal Information or Non-identifying Information, and our policy regarding such Content is described in the ePacket Content paragraph below.

Nothing in this Privacy Policy will prevent The Company from disclosing any of the above-described information to the extent required to comply with an applicable rule of law, a request of a government agency, or any other valid legal process (referred to collectively as a "Legal Process").

Cookies

Cookies are small text files that a Web site can send to a user's browser for storage on the hard drive. Cookies can make use of the Web easier by saving status and preferences about a Web site. Most browsers are initially set to accept cookies, but users can change the setting to refuse cookies or to be alerted when cookies are being sent. We use cookies to keep track of an individual's status as a logged-on user of the Services. Although failure to accept cookies will not interfere with the ability to interact with much of our Site, users will need to accept cookies in order to log-in and use the Services. The cookies are renewed every time a user uses the Services.

User Account Registration

Any visitor to the Site may register at our Site and create a User Account. All persons who wish to use the Services are required to create a User Account. You will provide us with certain information when you register at our Site (including your name, login name, password, and email address among other information). We will use such information for purposes related to the Services (including to provide support, send notices about maintenance downtime schedules and other administrative matters, or other matters pertinent to the Services). We may also use this information to let you know about other products and services that we think may be of interest to you and to include your entity name in a customer list. If you wish not to be so alerted, please contact the Webmaster at the email address below.

Updating/Deleting your User Account

You may update registration information you provided us at any time by going to the Passport Collaboration Portal Login screen and then clicking "Account Information." You may update or delete your User Account by contacting The Company at the address at the end of this Privacy Policy; however, by deleting your User Account, you will terminate whatever rights you then have to access the Services, and unless The Company has otherwise expressly agreed with you in writing, termination of your User Account will not result in refund of any fees paid to The Company. Unless you expressly request that your User Account be deleted, you agree that The Company may maintain your registration information indefinitely, under the then-most current Privacy Policy.

ePacket Content

Persons who use the Services may transmit information to The Company by mail, fax, email or by use of such Services (documents, files and other data), which information is collectively referred to as the "Content." The Company acts as a processor of such Content on behalf of users of the Services and their clients who are the data controllers with respect to the Content. All such Content is encrypted in the course of processing. Neither The Company nor any agent of The Company will in any way access or view the substance of any such Content except as required to provide the Services, process the Content pursuant to the Content recipient's business requirements, collect Non-identifying Information, enable you and your suppliers to comply with The Company's pricing programs then in effect, resolve a technical support issue at the request of the business or technical contact responsible for transmitting or receiving such Content or to comply with a Legal Process. In all cases, The Company will treat the Content as confidential information as set forth herein unless otherwise required by a Legal Process. The business or technical contact with respect to the Content in question is the individual so designated in the applicable Service Agreement or End User Agreement.

Partners and Other Sites

The Company may enter into business relationships with third parties ("Partners") from time to time in order to make such Partners' services and products available to you, and as a result, parts of this Site may be "co-branded" with the Partners' logos and links. We will not share any of the information we collect from you at this Site with such Partners unless we expressly inform you of such fact when we are collecting the information to be shared with the Partner from you. If you wish not to be so informed, please contact the Webmaster at the email address below. However, we have no control over the privacy policies, information gathered from you, or content of any Partner Web site or other third-party Web site that you may link to from our Site.

Financial Information

The Company charges fees for certain of the products and services available through the Site. To the extent you order such a product or service, we will collect information from you sufficient to enable you and your suppliers to comply with The Company's pricing programs then in effect. Such financial information is used only to bill you for ordered products and services.

Security

In order to protect the privacy of the Personal Information you supply us, The Company takes reasonable precautions to protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction. In the course of processing the data provided us, The Company and its network supplier implement industry standard security features including use of SSL encryption and Virtual Private Networks, firewalls, back-ups, passwords, and audits. You acknowledge, however, that no security system is completely error free, hacker proof, or failsafe, and as such The Company does not make any such warranty.

Modification to Terms

The Company reserves the right to change the terms and conditions of this policy relating to the Services at any time and shall notify you by posting an updated version of this policy on the Site. You are responsible for regularly reviewing this policy. Continued use of the Services after any such changes shall constitute your consent to such changes.

Contacting the Site

If you have any questions about this Privacy Policy, the practices of this Site, the use or disclosure of Personal Information or your dealings with this Site, or you wish to change your Personal Information and privacy preferences, please contact:

ELM Solutions, a Wolters Kluwer Company
3009 Post Oak Blvd., Ste. 1100
Houston, Texas 77056
Contact us online

The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information originating from the EU in accordance with the principles contained in this Privacy Policy. For complaints that cannot be resolved between The Company and the complainant, The Company has agreed to binding arbitration pursuant to the commercial arbitration rules of the American Arbitration Association as well as the Safe Harbor Enforcement Principle.

This Privacy Policy was last revised January 28, 2015.