Tornado Software Corporation. This Statement describes how Tornado Software Corporation and its affiliated companies (“Tornado Software”) collects, uses, and discloses certain personally identifiable information that it receives in the United States from the European Union (“EU Personal Data”). In particular, Tornado Software recognizes that the European Union has established strict protections regarding the handling of EU Personal Data, and Tornado Software therefore has elected to adhere to the US-EU Safe Harbor Privacy Principles (“EU Safe Harbor”) with respect to such EU Personal Data that it receives in the United States. For further background and information about the EU Safe Harbor, and to see Tornado Software's representation on the Safe Harbor List, please refer to the U.S. Department of Commerce's website at www.export.gov/safeharbor.

Disclosures of Personal Information. We may disclose Personal Information as necessary or appropriate in connection with any of the purposes for which we use Personal Information, including to subcontractors or service providers that help host or support the sites or otherwise provide technical assistance, fulfillment companies that help us to provide requested products or services, and business partners that help conduct seminars or otherwise provide requested products, services, or information. We also reserve right to disclose Personal Information in connection with the sale or transfer of all or part of the business. In these situations where we transfer Personal Information to these types of third parties, we require by contract that such third parties must not use or disclose the information for any purposes other than those specified in this Website Privacy Policy, and that such third parties must maintain commercially reasonable security measures to protect the Personal Information. In situations involving the sale or transfer of all or part of the business, we will seek to notify users of the ownership change by way of a prominent notice posted on our Web site. We also reserve the right to disclose Personal Information in connection with any judicial or administrative orders, law enforcement requests, or other applicable legal requirements.

Candidates for Employment with Clients. Tornado Software provides a wide variety of services and solutions to its business clients (“Clients”) that facilitate the selection, hiring, and internal mobility of individual candidates for specific employment (“Candidates”). In some instances, Tornado Software may obtain access to EU Personal Data about such Candidates in the course of providing the services and solutions. In other specific instances, Tornado Software may also obtain access to data about our Clients’ existing employees or end users in the course of providing support services to the Clients (“End Users”). Such data may include contact details, work history, educational history, work preferences, and other information, depending on the particular Client and application at issue.

Clients, Suppliers, and Business Partners. Tornado Software may obtain various types of EU Personal Data about employees and agents of our clients, suppliers, and business partners. Such data may include contact information (names, titles, addresses, phone and fax numbers, and email addresses); information about products and services ordered or provided; financial and payment information; user ID, passwords, and information collected through Internet-based and e-commerce activities, and other transaction-related data.

Tornado Software may use these types of EU Personal Data for business purposes, including to deliver or provide products or services; to establish or maintain client and business relationships; to provide access to Internet-based and e-commerce activities; to perform accounting functions; and to conduct other activities as necessary or appropriate in connection with the servicing and development of the business relationship.

Other Necessary Disclosures. Tornado Software may disclose EU Personal Data to business partners and subcontractors as necessary in connection with the performance of requested services or solutions, or as otherwise appropriate in connection with a legitimate business need. Tornado Software may also disclose EU Personal Data as necessary in connection with the sale or transfer of all or part of the business. In these situations, Tornado Software will require the recipient of the data to protect the data in accordance with the relevant principles in the EU Safe Harbor, or otherwise take steps to ensure that the EU Personal Data is appropriately protected. Tornado Software may also disclose EU Personal Data where required or permitted by law, or where Tornado Software believes that such disclosures are appropriate in connection with a law enforcement request.

E-mail: info@tornado-software.com
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