Afognak Native Corporation and its subsidiaries Alutiiq, LLC, Afognak Commercial Group, LLC, and Alutiiq Professional Consulting, LLC, and their various subsidiaries (collectively, the “Company”), respect your privacy and treat the information you provide us, including your Personal Information (“PI”) and Sensitive Personal Information (“SPI”), with care.
This Privacy Statement (the “Privacy Statement”) describes our policies and practices regarding the collection, use, and disclosure of PI or SPI you submit, or we obtain, in connection with your use of any of our publicly accessible websites (our “Sites”). It also provides insight into our collection of PI and SPI through other information channels, both physical and electronic. By accessing or visiting one of our Sites, you indicate your understanding that the collection, use, and disclosure of your information is subject to the terms of this Privacy Statement.
This Privacy Statement provides information as to how our Company collects, protects, and uses PI/SPI from visitors to our Sites or that we collect in the course of performing our business activities of providing products and services to our customers (our “Services”). It explains how we collect, use, and disclose information collected from you and the rights and choices available to you.
Your use of any of our Sites which are linked to this Privacy Statement is subject to this Privacy Statement. Please read this Privacy Statement carefully before using one of our Sites or submitting information to us. If you do not consent to the collection, use, and disclosure of your PI/SPI as described in this Privacy Statement, please do not provide us with such information. However, not providing necessary information as a part of your use of any of our Sites may limit our ability to deliver the products or services you intend to order or the information you are requesting.
Personal and Other Information We Collect from You and Others
Through your interaction with us, the accessing of our Sites, or receiving the benefits of our Services, our Company may collect PI or SPI. These two types of information are described as follows:
- PI is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. PI may include your name, physical address, telephone number, e-mail address, emergency contact details, company affiliation, and associated interests.
- SPI is information which, if compromised could cause you financial or other significant personal damage. SPI may include your social security, driver’s license, state identification card, or passport number, or your account login credentials and codes allowing access to your account.
Our Company may also collect “Other Information” through your interaction with and the use of our Sites and receipt of our Services. As examples, Other Information may include browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic or geo-location information, and statistical or aggregated data.
Statistical or aggregated data does not directly identify a specific person, but it may be derived from PI/SPI. And in some instances, we may combine Other Information with PI/SPI. In such cases, we will treat the combined information as PI/SPI, as appropriate.
Sources of Personal Information.
The categories of sources of PI or SPI are described below. The examples provided are for illustration purposes and are not exhaustive.
- You. Examples of when we collect that information include:
- During a website visit or completed form, or when you visit us at one of our locations or events.
- If you provide PI/SPI through our Sites using our online contact forms, we store the PI and, in some limited cases, SPI you provide to assist us in responding to your requests, in locations protected by our Corporate Cybersecurity Protection program.
- If you upload or share a photo, submit a request, submit information, or post other digital content through one of our websites, applications or via social media interactions on third party websites like Facebook or Twitter.
- If you apply for a job with our Company, the PI/SPI we receive from you is used for employment consideration and other human resource purposes, such as communicating with you in writing, by telephone, or online; evaluating your application; analyzing our staffing needs and practices; or supporting other actions related to our hiring process and employee administration. We may combine your data with research tools and information from other sources. Unless you request otherwise, we may keep your PI/SPI for future consideration, unless you request that we do not do so.
- Your friends and family. Such as when they provide your information through one of our refer-a-friend type features or programs. Persons who share such information in connection with those features or programs should only submit email addresses of individuals with whom they have a close personal or family relationship, who would be interested in receiving the communication, and who have authorized the sharing of their email address
- Cookies, social media, and related services. Information is gathered during your interactions with our Sites either directly by your inputs or through the capture of information gathered when you accept “cookies” during your visit to our Sites.
Information We Collect by Automated Tools
When you access one of our Sites, we may collect other information by automated means, including using cookies, web server logs, and third-party analytics. By accessing one of our Sites, you agree to the collection and use of non-PI or non-SPI in accordance with this Privacy Statement. Non-PI and non-SPI categories include Statistical, Usage, and Tracking Cookies. Each are discussed below.
- Statistical Data. To monitor use of one of our Sites and improve its quality, we may compile statistical information concerning the use of the specific Site through analytics services. Examples of this information may include:
- The number of visitors to a particular Site, or to sections or pages within the specific Site.
- Patterns of traffic flowing through the specific Site.
- Length of time spent by a visitor to s particular Site, or in sections or pages of that Site,
- The other sites that refer visitors to each particular Site.
- The pages of a particular Site that visitors frequently use as entry and exit points.
- Utilization of the browser and operating systems and versions used by visitors to a specific Site.
- Analytics services which may transfer this information to service providers or other third parties in case of a legal obligation or if a service provider processes data on behalf of that service.
- Usage Data.
- We may also collect information on how our Sites are accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g., your dynamic IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
- While this information can be associated with the IP address belonging to the computer you used at the time you visited one of our Sites, the dynamic nature of assigning IP addresses means it will not be associated with you as an individual.
- Tracking Cookies Data.
- We use cookies and similar tracking technologies to track the activity on our Sites and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier.
- Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used, such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
- You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of some of our Sites.
- Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Sites.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings as you use each of our Sites.
- Security Cookies. We use Security Cookies for security purposes.
- Information Logging. Additionally, our web servers may log Other Information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located.
- We may also record Other Information such as the address of the webpage that referred you to one of our Sites and the IP address of the device you use to connect to our Sites.
- Additionally, we may log Other Information about your interaction with our Sites, such as pages you visit.
- Web-Analytics. We may also use third-party web analytics to help us analyze how users engage with our Sites.
- This other information collected will be disclosed to, or collected by, these third-parties.
- However, it is important to note that we do not disclose, share, or sell PI or SPI to third parties.
- All of the information we capture through automated means is “anonymized” before it is released. Simply stated, we ensure that it can’t be tracked back to you or anyone else before it leaves our Company’s control, unless you specifically give us permission.
- Summary of Use of Data: In addition to the purposes set out above, we use the collected non-PI and non-SPI for various purposes:
- To provide and maintain our Service.
- To notify you about changes to our Service.
- To allow you to participate in the interactive features of our Sites when you choose to.
- To provide customer support.
- To gather analysis or valuable information so that we can improve our Service.
- To monitor the usage of our Service.
- To detect, prevent and address technical issues.
How We Use Your Personal Information
In accordance with applicable laws, our Company will use the PI or SPI we collect about you only for the purpose it was collected, for compatible purposes as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Privacy Statement. For example, we may use your data:
- To open and manage an account on one of our Sites and to provide the service or information you requested to receive.
- To respond to your requests for information about the Company or related to activities, opportunities, events, or products appearing on one of our Sites.
- To communicate with you. We may send you messages about the availability of our Service, Site, security, or other service-related issues. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.
- To inform you of the products, services, events, or activities that we think may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed.
- We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means.
- If you no longer wish to receive a communication from the Company, you have the option of unsubscribing from our mailing list for that communication.
- To contact you in the event of an emergency.
- For our research and development efforts. We may use data, including public feedback and surveys, to conduct research and for the development of particular Sites, services, products, and information we provide.
- To ensure your information is accurate and to personalize our communications to you. For example, we may aggregate your PI/SPI with data from third-party sources for purposes of keeping information up to date. We may also rely on information from third parties in order to provide better, more personalized service. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal or share and use it as described elsewhere in this Privacy Statement.
- To evaluate your qualifications for employment and contact you, as appropriate, for employment opportunities.
- To process applications for employment, as well as to evaluate and improve our recruiting efforts.
- To support human resource functions including employee administration and analysis of hiring and recruitment processes.
- To submit bids for proposals and contracts from governmental or private entities.
- To identify, prevent, and protect against cyber-attacks and other security events, espionage, fraud, unlawful activity, claims, and other liabilities, and to maintain the safety and security of our Sites, products, technology assets, and business.
- To comply with and enforce applicable legal requirements and standards consistent with industry practices and our policies.
- For other everyday business purposes. For example consumer preferences product stockage, Site administration, quality control, fulfillment, analytics, fraud prevention, reporting, and legal compliance.
- To help maintain the safety, security, and integrity of our Sites, products and services, databases and other technology assets, and business
- For testing, research, analysis, and product development, including to develop and improve our Sites, products, and services.
- As described to you when collecting your PI/SPI (see below “Point of Collection”).
- To enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
- To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
- As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PI/SPI held by us about our users is among the assets transferred.
Information We Share
It is our Company policy not to sell PI or SPI collected from customers, clients, employees, shareholders, contractors, subcontracts, or consultants. Similarly, we do not exchange or trade PI/SPI for any non-financial consideration. We will not disclose your personal data we collect through any of our Sites except with your consent or as set forth within this Privacy Statement. We may disclose your PI or SPI to our corporate affiliates and Service Providers, as we deem necessary to carry out the purposes described below:
- Service Providers. We employ other companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. These Service Providers have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. It is our Company policy to share your information only with our service providers in accordance with written contracts requiring our service providers to keep the information confidential:
- As you direct for in your specific request.
- To manage a specific Site.
- To provide you with products, services, or offers.
- To enhance our services by, among other methods, obtaining assistance with providing more personalized services to you through analytics and other technologies.
- To protect our interests and legal rights, such as through responding to subpoenas and defending litigation.
- To protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.
We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data.
- Legal Process, Security, Defense, Protection. It is possible that we will need to disclose PI or SPI if required by law, subpoena, or other legal process. Additionally, we may disclose PI/SPI if we have a good faith belief that disclosure is reasonably necessary to:
- Demonstrate our relationship with you.
- Investigate, prevent, or take action regarding suspected or actual illegal activities or to assist law enforcement agencies.
- Protect the security or integrity of a specific Site or all of our Sites.
- Investigate and defend ourselves against any third-party allegations or claims.
- Protect the rights and safety of others.
- If required by law or through a legal process.
- When we submit bids for proposals and contracts from governmental or private entities.
- When formally requested by law enforcement authorities or other government entities.
- When we believe disclosure is necessary or appropriate to prevent harm or financial loss.
- In connection with an investigation of suspected or actual espionage, cybersecurity, or security events, or other fraudulent or illegal activity.
- Any other legal purpose.
- Change in Control or Sale. We may disclose, sell, assign, or license your PI/SPI in connection with certain business transactions, such as a sale, acquisition, merger, or change in control of the Company, or in preparation for any of these events. In such cases, we will take appropriate steps under the circumstances and to the extent possible to ensure that the recipient will apply privacy protections substantially similar to those established by this Privacy Statement. Any entity that acquires all or substantially all of the Company’s assets will have the right to continue using your data consistent with this Privacy Statement or as otherwise agreed to by you.
Online Recruiting Information
We may collect online recruiting information from individuals who visit our Sites and are interested in pursuing job opportunities with our Company. To this end, our Sites may provide you with the opportunity to review and apply for available positions listed in an online jobs database and assist you in the event you need a disability reasonable accommodation.
If you choose to proceed and gain access to this database through one of our Sites, you will be linked to a website hosted and maintained by one of our service providers (“Online Recruiting Site”). The Online Recruiting Site will allow you to provide information (e.g., your resume, contact information and identification of our Company positions of interest) that will be shared with our Company and used to evaluate your eligibility for employment and contact you as appropriate. Please note that our Service Provider is responsible for operating the Online Recruiting Site, and their privacy practices may be different than our Company’s. We encourage you to review such privacy policies and terms of use posted on the Online Recruiting Site prior to submitting any PI/SPI in connection with your employment application.
Privacy of Children
Our Company Sites are not directed to children as the products and services on this Site are intended for persons 18 years of age and older. Our Company does not knowingly collect, use, or disclose any personally identifiable information from children. If you are concerned about your child’s use of any of our Sites, you may use web-filtering technology to supervise or limit access to any or all of our Sites.
If you are a parent or guardian and you are aware that your child has provided us with PI or SPI, please contact us. If we become aware that we have collected PI or SPI from children without verification of parental consent, we take steps to remove that information from our servers. Again, if you are concerned about your child’s use of any of our Sites, you may use web-filtering technology to supervise or limit access to any of our Sites.
Social Media Plugins (Social Plugins)
Some of our Sites use social media plugins (e.g. Facebook) to enable you to easily share information with others. When you visit on of our Sites and access the social media plugin, the operator of the plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Site. If you are logged into the social media website (e.g. Facebook) while browsing our Site, the plugins allow that social media website to share data about your activities on our Site with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website. We do not control any of the content once it is captured within social media plugins. For more information about social media plugins/social plugins from other media websites, you should refer to those sites’ privacy and data/information sharing statements/policies.
How We Protect Personal Information
Our Company is committed to protecting your PI/SPI from unauthorized access, use, or disclosure. That said, no system for safeguarding personal or other information is 100% secure and even though we have taken steps to protect your personally identifiable information from being intercepted, accessed, used, or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with PI/SPI.
However, we take a number of steps to safeguard the security of PI/SPI obtained through each of our Sites. Our Company policy is to maintain administrative, technical, and physical controls to reasonably safeguard data from unlawful use, unauthorized access, or disclosure. Additionally, we use data encryption when data is transmitted over the Internet to one of our Sites. Finally, individuals who have access to confidential and otherwise nonpublic data are required to maintain the confidentiality of such information.
Points of Collection
Our Company provides this Privacy Statement to the consumers of our products and services in order that they may understand our Company’s approach to the management, use, and control of information we receive from and about you. We also provide more specific information at each point where you are asked to provide such information. This is called a “Point of Collection Notice” and will be found on:
- Specific pages on our Sites where information is requested.
- On physical forms used to collect PI or SPI.
- At physical locations using quick response (QR) code scanners which request this type of information.
Changes to Privacy Statement
Our Company may modify this Privacy Statement at any time. We will notify users of changes by posting changes to our Sites or by other appropriate means. We recommend you visit this page frequently to determine if any changes have occurred. You can determine when this Privacy Statement was last revised by referring to the “Effective Date” at the top of this page. Any changes to this Privacy Statement will become effective upon posting on our Sites. A user’s continued use of our Sites or provision of PI/SPI to use our Sites following such changes indicates acceptance to the revised Privacy Statement.
In the event the Company’s policy regarding sale of PI/SPI were to change, you would be afforded the opportunity to opt-out of the sale of your company data or PI/SPI in advance of any such action.
Links to Other Websites
This Privacy Statement applies only to our Sites. You should be aware that through links you may be directed to other websites that we do not control. Our Company has no control over the privacy notices, policies, or practices of these other websites, and is not responsible for the privacy practices or the content of websites to which we link, list, rank or identify by means of a search. Our Company takes no responsibility for the products, services, policies, or actions of third-parties or the content of third-party websites. When you leave one of our Sites and go to a third-party website, we encourage you to read the privacy policies and other notices posted.
Your Rights and Choices
Within some of our Sites, you can sign up to receive Company e-mail alerts for information that interests you, such as the latest special offers from our retail sales subsidiaries. We offer “opt-in” lists so you can sign up and sign off at any time. To unsubscribe, simply reply to the email address on the bottom of every email we send you.
Consent to Data Transfer
While our Company has business activities in many countries around the globe, we are headquartered in the United States. Data and information collected from your visit may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you proceed to use this or any of our Sites, your PI/SPI may be transferred to or accessible by entities or individuals in the United States and processed according to the terms described in this Privacy Statement.
PI/SPI collected by our Company may be stored and processed in your region, in the United States, and/or in any other country where our Company or our Service Providers operate facilities. Typically, the primary storage location is in the United States or a customer’s region (which may also be the United States), often with a backup to a data center in a different region. Storage location(s) are chosen in order to operate efficiently, improve performance, and create redundancies to protect the data in the event of an outage or other problem.
Our Company, or our Service Providers may, at some point, transfer PI of individuals living or working within the European Union (EU) or countries included in the European Economic Area (EEA) to other countries. Some of those countries may not yet have been determined by the European Commission to have an adequate level of data protection. For example, those countries’ laws may not guarantee you the same rights, or there may not be a government authority capable of addressing your concerns. We will take all the steps reasonably necessary to ensure that your information and data are treated securely and in accordance with this Privacy Statement, and no transfer of the information or data collected during your visit will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.
By continuing to use this or any of our Sites, you authorize our Company and its Service Providers to transfer your PI/SPI to – or make it available in – destinations outside your home country and to process it according to this Privacy Statement. You may contact us at privacy@afognak.com for more information about the safeguards used protect your PI or SPI if it is transferred outside of your country of residence.
Your California Privacy Rights
This section of this Privacy Statement supplements and amends the information contained in the primary Privacy Statement, set out above, with respect to California residents. This California Privacy Supplement (“CASUP”) applies solely to individuals, visitors, users, and others who are natural persons and residents of the State of California (“consumers” or “you”). The CASUP is adopted in part to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”). Any terms defined within the CCPA or the CPRA have the same meaning when used within this CASUP. The other provisions of this Privacy Statement continue to apply except as modified in the CASUP.
- Information We Collect. See the sections titled “Sources of Personal Information” and “Information We Collect by Automated Tools” for a discussion on the types of information we collect.
- Consumer Rights. Pursuant to the CCPA and the CPRA, and as detailed below, consumers have various rights with respect to their PI/SPI.
- Right to Request Deletion. You have the right to request that we delete your PI/SPI from our records and direct any service providers or contractors to delete your PI/SPI from their records, subject to certain exceptions. Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers or contractors to delete your PI/SPI from our records.
- Right to Request Information. You have the right to request that we disclose the following to you as it relates to the 12-month period preceding its receipt of your verifiable consumer request:
- The categories of PI/SPI we have collected about you.
- The categories of sources from which the PI/SPI was collected.
- The business or commercial purpose for collecting PI/SPI.
- The categories of PI/SPI we disclosed for a business purpose.
- The categories of third parties with whom we disclose PI/SPI.
- The specific pieces of PI/SPI we collected about you.
Upon receipt of a verifiable consumer request, and as required by the CCPA, we will provide a response to such requests.
- Right to Request Correction of Inaccurate Information. You have the right to request that we correct inaccurate PI/SPI that we maintain. Upon receipt of a verifiable consumer request, and as required by the CCPA, we will provide a response to such requests.
- Right to Direct the Company to Limit the Use of SPI. You have the right to direct that we limit the use of SPI we collect about you to:
- (i) uses that an average consumer would expect are reasonably necessary to provide the products and/or services you have requested,
- (ii) perform certain other activities permitted under the CCPA, and
- (iii) what is permitted by applicable law.
- Right to Direct the Company to Limit the Use of SPI. You have the right to direct that we limit the use of SPI we collect about you to:
Your right to direct the Company under this paragraph applies only to SPI that we collect or processed for the purpose of inferring characteristics about you.
- Right to Nondiscrimination. We will not discriminate against you in violation of the CCPA or CPRA for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of products or services if you exercise your rights under the CCPA.
- Submitting Consumer Rights Requests. To exercise your rights in this section, please email your request to: privacy@afognak.com or submit a request online as indicated in the “How to Contact Us” section below. You may also contact us through our toll-free number at (888) 292-9580 where you can ask to be connected to our Corporate Privacy Team. We reserve the right to only respond to verifiable consumer requests. A “verifiable consumer request” is one made by any individual who is:
- The consumer who is the subject of the request,
- A consumer on behalf of the consumer’s minor child, or
- By a natural person or person registered with the California Secretary of State authorized to act on behalf of a consumer.
- Identify Verification. If the Company requests, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a consumer.
- You will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt, but we may require an extension of up to forty-five (45) additional days to respond and we will notify you of the need for the extension.
- If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to PI/SPI collected on and after January 1, 2022, and to the extent expressly permitted by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by the Company.
- The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.
- You may authorize a natural person, or a business registered with the California Secretary of State, to act on your behalf with respect to the right under this CASUP. When you submit a Request to Know or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
- Annual Requests. California residents are also entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal data to third parties for their direct marketing purposes in the preceding calendar year. That said, it is important to note that we do not share personal data with third-parties for their direct marketing purposes.
- Annual Notifications. During January of each year, the Company provides written notification to all Employees and Shareholders of the Company who are California residents. The notification includes the reason for the notification followed by a set of statements showing “Categories of Personal Information/Sensitive Personal Information Collected” and the related “Purposes Personal Information/Sensitive Personal Information is Used.” The notification also includes a statement regarding sharing of information with Service Providers and a contact phone number for additional information on CCPA/CPRA compliance and information being collected from Employees.
Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. Our company currently does not take action in response to these signals.
Your Japan Privacy Rights
This section of this Privacy Statement supplements and amends the information contained in the primary Privacy Statement, set out above. It is provided regarding Japan’s amended Act on Protection of Personal Information (APPI) and with respect to employees of our Company that are residents of Japan. This Japan Privacy Policy Supplement focuses heavily on the collection and holding of PI held in databases to support the needs of our employees and provide necessary reporting to relevant Government organizations in accordance with applicable laws and regulations.
Our Company does not directly collect information on other residents or citizens of Japan unless they individually visit our Sites. In such cases the notice at collection at the particular Site provides information on the type of Personal Information that is collected and how it is to be used.
Our Company respects the personal information of employees, and we handle that retained PI and “Special Care-Required PI”, as defined in the APPI in accordance with the following policy.
- Basic policy
- We fully recognize the importance of protecting your personal information. As such, we establish the following operating principles by which we handle employee’s personal information appropriately and strive to protect it.
- We handle your personal information within the scope of the purpose of use specified to you at the time it is collected. In addition, we will not disclose or provide your personal information to a third party except with your consent of the employee or with a justifiable reason.
- We will keep your personal information, which you have entrusted to us, accurate and up-to-date and will endeavor to prevent unauthorized access to your personal information, to include loss, destruction, falsification, and leakage of your personal information.
- Compliance with laws and regulations: When handling your personal information, we will comply with laws and regulations regarding the protection of personal information.
- Purpose of assembling personal information: When we receive personal information from you and other employees, we will specify the purpose and limit the use within that range. If it becomes necessary to use your Personal Information beyond the scope of the purpose specified when you provided it, we will inform you in advance to obtain your consent, and we will use it only within the scope of that consent.
- Protection and management of personal information: We will implement an appropriate and rational level of safety measures against unauthorized access and falsification of your personal information from the outside to prevent leakage, and also to prevent unauthorized use and leakage within the company. We will endeavor to take measures continuously as set forth in our Company’s Consumer Information Privacy Program.
- Disclosure of personal information and provision to third parties: We will not disclose personal information to third parties (as defined in the Japan’s APPI) without the consent of the employee. This information is used almost exclusively for employment, human resource, and benefits management purposes. In addition, personal information may be disclosed without the consent of the Employee even if the disclosure is requested by an institution such as a court, police, or lawyer, as required by law.
- Improvement of Internal Systems: We will provide education on the handling of your personal information within the company and strive to continuously protect your personal information.
- Inquiries, corrections, and deletions regarding disclosure of personal information: If you want to confirm the personal information that we keep, we will disclose it only if we can confirm that you are the person. As a result, if there is an error or change in your personal information and you request correction or suspension of use, we will correct or delete it unless required to provide you the employment, human resource, or benefits support you require.
Your Mexico Privacy Rights
This section of this Privacy Statement supplements and amends the information contained in the primary Privacy Statement, set out above. It is provided regarding Mexico’s Federal Law on the Protection of Personal Data held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) (“The Law”) and with respect to employees of our Company that are residents or citizens of Mexico. This Mexico Privacy Policy Supplement focuses heavily on the collection and holding of PI held in databases to support the needs of our employees and provide necessary reporting to relevant Government organizations in accordance with applicable laws and regulations.
Our Company does not directly collect information on other residents or citizens of Mexico unless they individually visit our Sites. In such cases, the notice at collection at the particular Site provides information on the type of Personal Information that is collected and how it is to be used.
Our Company respects the personal information of employees, and we handle that Retained Personal Information and Special Care-Required Personal Information in accordance with the above Privacy Statement, as supplemented and amended in this section. As such, this Mexico Privacy Rights Supplement clearly describes how and for what purposes we intend to manage the personal information that our employees provide us.
Company Information
Afognak Native Corporation, with the following address: 3909 Arctic Blvd, Suite 500, Anchorage, Alaska, United States of America is the entity responsible of the treatment of your personal data, its use, and its protection as an employee of the Company.
Purposes for Collection and Processing of Personal Information
We obtain your personal information when it is given personally, by phone, by electronic means, and through other sources allowed by the Law. The information types that we obtain are as indicated in the privacy statement above and as indicated on the notices at collection.
Your Access, Rectification, Cancellation, and Opposition (ARCO) Rights
You have the right to request the access to, rectify, cancel, and oppose the management of your Personal Information (the “ARCO Rights”). Furthermore, you have the right to request the revocation of your given consent, as well as limit the use of your Personal Information.
In order to exercise your rights, we ask that you send an e-mail to privacy@afognak.com, so we can send you the appropriate request form, which you should complete and submit.
For security purposes and in compliance with the Law, it is mandatory that all request forms be accompanied by the information necessary for us to identify the applicant, and if applicable his or her legal representative. In response to your email request, we will advise you of the necessary documentation to adequately identify you and to validate your request.
Additionally, you have the right to revoke your consent to the retention of any of your Personal Information which is not required for the provision of services related to your employment with the Company. The procedure, requirements, and contact information needed for you to revoke your consent shall be the same as the procedure needed to exercise your ARCO Rights established above.
If you have not expressed disapproval of the terms mentioned in the Privacy Statement above or this Mexico Privacy Rights Supplement, it shall be understood as given consent to the retention and processing of your Information.
Transfer of Information
As indicated in the Privacy Statement above, our Company has business activities in many countries around the globe, but we are headquartered in the United States of America. Data and Information collected from you will be maintained on computers located outside of your state, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Thus, your personal information may be transferred to or accessible by entities or individuals in the United States of America and processed according to the terms described in the Privacy Statement and this Mexico Privacy Rights Supplement.
Your Personal Information may also be subject to be transferred, without your prior consent when the transfer is made between the Company and its subsidiaries or affiliated companies or to any company providing services under contract to the Company to support your employment experience in accordance with the provisions of the Law, its Regulations, and its Guidelines.
Update of Privacy Statement and Notices
From time to time and in compliance with The Law, the Company may modify or update our Privacy Statement or this Mexico Privacy Policy Supplement. In which case, you may check any updates through our website at https://privacy.afognak.com.
Processing of Sensitive Personal Data
At any time, you may contact Afognak Native Corporation with questions or concerns about this Privacy Statement at privacy@afognak.com. Written responses may also be submitted to:
The Company does not proactively obtain data considered as sensitive by The Law, such as religion, health situation, sexual preferences, political opinion, and similar data. We ask that you do not send information of this nature to us. In case you voluntarily provide us with this information, and we receive it or register it in our systems, the Company will only use it in the extent that such information might be essential to provide you with the service you requested from us.
How to Contact Us
Afognak Native Corporation (Attn: Corporate Privacy Officer)
3909 Arctic Boulevard, Suite 500
Anchorage, AK 99503
Phone: (907) 222-9500
Toll-Free Phone Number: (888) 232-9574
Fax: (907) 222-9501