Safe Harbor Privacy Policy

The United States Department of Commerce, in consultation with the European Commission and Switzerland, developed a "safe harbor" framework set forth in a set of seven privacy principles and fifteen frequently asked questions and answers (FAQs) (collectively, the "Safe Harbor Principles").

The enterprise solutions division ("ES") of NTT America, Inc. ("NTTA") or ("NTTA-ES") complies with the U.S.-EU Safe Harbor Framework and the U.S. Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. NTTA-ES has certified that it adheres to the Safe Harbor Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. This policy outlines ES's general policy and practices in implementing the Safe Harbor Principles. If there is any conflict between provisions in this policy and those in the Safe Harbor Principles, the provisions in the Safe Harbor Principles will govern. To learn more about the Safe Harbor program, and to view NTT America’s certification, please visit http://www.export.gov/safeharbor/.

This policy applies to all personal information that ES handles, including contact information that is gathered before and during the provisioning of customer solutions and also during on-going support of these solutions.

For purposes of this policy, "personal information" means information that (i) is transferred to NTTA-ES, including any such information transferred from the European Union or Switzerland to the United States; (ii) is recorded in any form; (iii) is about, or pertains to, a specific individual; and (iv) can be linked to that individual. "Personal information" does not include information that pertains to a specific individual, but from which that individual could not reasonably be identified.

Protected health information ("PHI") is individually identifiable health information maintained or transmitted in any form that is created or received by a health care provider and relates to past, present or future health information of an individual.