AS OF OCTOBER 6, 2015, THE SAFE HARBOR FRAMEWORK UNDER WHICH QVC ADOPTED THIS SAFE HARBOR STATEMENT IS NO LONGER CONSIDERED A VALID DATA TRANSFER MECHANISM BY EU AUTHORITIES. QVC'S SAFE HARBOR CERTIFICATION WILL EXPIRE ON JULY 27, 2016. AT THIS TIME, QVC IS MAINTAINING THIS LEGACY SAFE HARBOR STATEMENT FOR INFORMATIONAL PURPOSES ONLY. IN PARALLEL, QVC EMPLOYS ALTERNATIVE MECHANISMS FOR THE LAWFUL TRANSFER OF PERSONAL DATA FROM THE EUROPEAN UNION TO THE USA.
It is QVC's policy to respect and protect Personal Information collected or maintained by or on behalf of QVC. In furtherance of our commitment, QVC has certified its adherence to the US-EU Safe Harbor Agreement regarding Personal Information collected in the European Economic Area (EEA) in support of QVC's commercial operations. QVC adheres to the Safe Harbor privacy principles and the "Frequently Asked Questions" document, as agreed to by the U.S. Department of Commerce and the European Commission. To learn more about the Safe Harbor program, and to view QVC's certification, please visit http://www.export.gov/safeharbor/.
This Safe Harbor Statement sets forth the principles under which QVC manages the processing of Personal Information that it may receive from its customers in the EEA in support of its commercial operations. In connection with QVC's commercial operations, including but not limited to fulfillment of product orders, website and e-mail communications, and customer service, QVC may now and/or in the future transfer or provide access to Personal Information regarding citizens of the EEA outside of the EEA.
The following terms are used throughout this Safe Harbor Statement and are defined as follows:
"Customer" means any European citizen, residing in the European Economic Area, who is a potential or actual customer of QVC and whose information is transmitted outside the EEA.
"Service Provider" means any third party that may process a customer's Personal Information under the instructions of, and solely for, QVC or to which QVC discloses Personal Information on its behalf.
"QVC" means QVC, Inc., including its wholly owned subsidiaries that are incorporated in any state or territory of the United States.
"Personal Information" means any information or set of information in any form that identifies or can reasonably be used to identify a natural person. Personal Information does not include anonymized information or information that is reported in the aggregate.
"Sensitive Personal Information" means Personal Information that reveals race, ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, any information that concerns health or sex life, or information relating to the commission of a criminal offense.
QVC notifies customers in the EEA about the types of Personal Information it collects about them, the purposes for which it collects such information, the types of third parties to which it discloses such information, and how to contact the organization with any inquiries or complaints. Notice will be provided in clear and conspicuous language at the time of collection, or as soon as practicable thereafter, and before QVC uses or discloses the information for a purpose other than that for which it was originally collected.
In the event a customer's Personal Information is to be used for a new purpose incompatible with the purposes for which the information was originally collected or subsequently authorized or is to be transferred to a third party exercising independent control over the information, individuals are given, where practical and appropriate, an opportunity to decline to have their Personal Information so used or transferred. In the event that the information used for a new purpose or transferred to the control of a third party is Sensitive Personal Information, the individual's explicit consent will be obtained prior to the use or transfer of the information.
QVC will only transfer a customer's Personal Information to a Service Provider where the Service Provider has given assurances that they provide at least the same level of privacy protection as is required by these privacy principles. Where QVC has knowledge that a Service Provider is using or sharing Personal Information in a way that is contrary to these principles, QVC will take reasonable steps to prevent or stop such processing.
QVC takes reasonable and appropriate administrative, technical, and physical precautions to protect the confidentiality, integrity, and availability of a customer's Personal Information, whether in electronic or tangible, hard copy form.
Customers have reasonable access to their Personal Information and may request corrections, deletions, or additions, as appropriate, and except where the burden or expense of providing access would be disproportionate to the risks to the customer's privacy or where the rights of persons other than the customer would be violated.
QVC limits the collection, usage, and retention of customer Personal Information to that which is germane for the intended purposes for which it was collected, and takes reasonable steps to ensure that all Personal Information is reliable, accurate, complete, and current. QVC depends on its customers to keep Personal Information reliable, accurate, complete, and current.
QVC has put in place mechanisms to verify ongoing compliance to these Safe Harbor principles. Any Service Provider that violates these Safe Harbor principles will be subject to disciplinary procedures by QVC.
In case of disputes, customers are able to seek resolution of their questions or complaints regarding use and disclosure of their Personal Information in accordance with the principles contained in this Safe Harbor Statement. If you feel that QVC is not abiding by this Safe Harbor Statement or is not in compliance with the Safe Harbor principles, please contact QVC at the contact information provided below. In addition, QVC has agreed to cooperate with Judicial Arbitration Mediation Service (JAMS).
JAMS will act as liaison to QVC to resolve any inquiries.
QVC adheres to these Safe Harbor principles, except as required or allowed by law, to meet legal, governmental, law enforcement or national security obligations, or to protect the health or safety of an individual.
Please contact QVC with any questions concerning this Safe Harbor Statement at:
Attn: General Counsel
1200 Wilson Drive
West Chester, PA 19380
This Safe Harbor Statement may be amended consistent with the requirements of Safe Harbor. When QVC does update the Safe Harbor Statement, QVC will also revise the "Last Updated" date at the bottom of this Safe Harbor Statement. Any material changes to this Safe Harbor Statement will also be posted on QVC.com.
Last Updated: July 14, 2016