Safe Harbor Privacy Policy


The European Union (EU) has adopted a Directive on Personal Data Protection (the EU Directive). The EU Directive requires EU member states to adopt laws protecting Personal Data collected within their borders and permits transfers of Personal Data from the EU only to countries that have enacted laws or adopted other arrangements that are deemed adequate to protect Personal Data under principles established in the EU Directive. The US Department of Commerce and the European Commission have agreed on certain Safe Harbor Principles and related procedures in conformity with the EU Directive that US companies can elect to follow to adequately protect Personal Data transferred from the EU to the US.


PAGUS LLC  d.b.a ITOS is committed to protecting the privacy of individuals who entrust ITOS with their Personal Data, including ITO’s customers, employees, and business partners. Consistent with this commitment to protect personal privacy, ITOS adheres to the Safe Harbor Principles for the purpose of safeguarding Personal Data transferred on ITO’s behalf from the EU to the US. This Safe Harbor Privacy Policy (the Policy) describes our practices for implementing the Safe Harbor Principles, and the Policy applies to all Personal Data received by ITOS in the US from the EU via a transmission in any format, including electronic, paper, or verbal.


For purposes of this Policy, the following definitions apply:

Personal Data means any information or set of information that identifies an individual person or is used by ITOS to identify an individual. Personal Data includes:

  • First name and last name
  • Job title
  • Company name
  • Email address
  • Phone number

Privacy Principles

ITOS has implemented the privacy principles and practices set forth in this Policy to comply with the Safe Harbor Principles.


If ITOS stores Personal Data directly from individuals in the EU, it will furnish its clients and individuals with a notice informing them of: a) the purposes for which it collects and uses their Personal Data, b) a description of any third parties, to which their Personal Data may be disclosed or transferred, and c) their right to exercise the opt-out choice for Personal Data or the opt-in choice for Sensitive Personal Data. The Notice will be provided to individuals in clear and conspicuous language when Personal Data is first collected from them, or as soon thereafter as practicable.

Access To and Integrity of Personal Data

ITOS will use and process Personal Data only in ways that are compatible with the purposes for which it was collected from individuals and consistent with the Notice and opt-out or opt-in choices exercised by the individuals from whom the Personal Data was collected. ITOS will take reasonable steps to ensure that Personal Data is accurate, complete, current, and reliable for use to achieve the purposes for which the Personal Data was collected. Upon request, ITOS will permit individuals to access or review their Personal Data that is in the possession or control of ITOS. ITOS will also take reasonable action to permit individuals to make corrections, additions, or deletions of their Personal Data if it is demonstrated to be inaccurate or incomplete.


ITOS will take reasonable precautions to protect Personal Data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.


ITOS will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that ITOS determines to be in violation of this Policy will be subject to appropriate disciplinary action.

Dispute Resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to ITOs Office at the address given below. ITOS will investigate and attempt to resolve complaints and disputes regarding use and disclosure of individual’s Personal Data in accordance with the principles contained in this Policy. For complains that cannot be resolved between ITOS and the complainant, ITOS has agreed to participate in the dispute resolution procedures of the

panel established by the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles.

Contact Information

Questions or comments regarding this Policy should be submitted to the following person by mail as follows:

5 Revere Drive, Suite 200
Northbrook, Illinois 60062
Attention: Jose Maria, Managing Director
Telephone: 847-494-4025

Changes To This Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on ITOS’ website ( ( ( for sixty (60) days whenever this Policy is changed in a material way.

Revised Date: June 23, 2017