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International Data Management, a DMH Owned Company (hereinafter the "Companies")
respects individual privacy and values the confidence of their customers,
employees, consumers, business partners and others. The Companies strive to
collect, use and disclose personal information in a manner consistent with the
laws of the countries in which they do business, and pride ourselves on
upholding the highest ethical standards in our business practices. This Safe
Harbor Privacy Policy (the "Policy") sets forth the privacy principles that the
Companies follow with respect to personal information transferred from the
European Union (EU) to the United States.
SAFE HARBOR
The United States Department of Commerce and the European Commission have agreed
on a set of data protection principles and frequently asked questions (the "Safe
Harbor Principles") to enable U.S. companies to satisfy the requirement under
European Union law that adequate protection be given to personal information
transferred from the EU to the United States. The EEA also has recognized the
U.S. Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001,
p.47). Consistent with its commitment to protect personal privacy, International
Data Management adheres to the Safe Harbor Principles. SCOPE
This Safe Harbor Privacy Policy (the "Policy") applies to all personal
information received by Direct Mail Holdings, or any Owned DMH Company in the
United States from the European Economic Area, in any format including
electronic, paper or verbal.
DEFINITIONS
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that collects or uses personal information under
the instructions of, and solely for, the Companies or to which the Companies
disclose personal information for use on their behalf.
"IDMI " means International Data Management a division of Mail America
Communications a DMH Company, Delaware based Corporation in the USA.
"Personal information" means any information or set of information that
identifies or is used by or on behalf of the Companies to identify an
individual. Personal information does not exclude information that is encoded or
anonymized, or publicly available information that has not been combined with
non-public personal information.
"Sensitive personal information" means personal information that reveals race,
ethnic origin, sexual orientation, political opinions, religious or
philosophical beliefs, or trade union membership, or that concerns an
individual's health. In addition, the Companies will treat as sensitive personal
information any information received from a third party where that third party
treats and identifies the information as sensitive.
"The Company" means Direct Mail Holding, LLC of which International Data
Management and their respective successors, subsidiaries, divisions and groups
are in the United States.
PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the Safe Harbor Principles.
NOTICE:
Where the Companies collect personal information directly from individuals in
the EU, it will inform them about the type of personal information collected,
the purposes for which it collects and uses the personal information, and the
types of non-agent third parties to which the Companies disclose or may disclose
that information, and the choices and means, if any, the Companies offer
individuals for limiting the use and disclosure of their personal information.
Notice will be provided in clear and conspicuous language when individuals are
first asked to provide personal information to the Companies, or as soon as
practicable thereafter, and in any event before the Companies use or disclose
the information for a purpose other than that for which it was originally
collected.
Where the Companies receive personal information from their subsidiaries,
affiliates or other entities in the EU, they will use and disclose such
information in accordance with the notices provided by such entities and the
choices made by the individuals to whom such personal information relates.
CHOICE:
The Companies will offer individuals the opportunity to choose (opt-out) whether
their personal information is (a) to be disclosed to a non-agent third party, or
(b) to be used for a purpose other than the purpose for which it was originally
collected or subsequently authorized by the individual.
For sensitive personal information, the Companies will give individuals the
opportunity to affirmatively and explicitly (opt-in) consent to the disclosure
of the information to a non-agent third party or the use of the information for
a purpose other than the purpose for which it was originally collected or
subsequently authorized by the individual.
The Companies will provide individuals with reasonable mechanisms to exercise
their choices.
DATA INTEGRITY:
The Companies will use personal information only in ways that are compatible
with the purposes for which it was collected or subsequently authorized by the
individual. The Companies will take reasonable steps to ensure that personal
information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS:
The Companies will obtain assurances from their agents that they will safeguard
personal information consistently with this Policy. Examples of appropriate
assurances that may be provided by agents include: a contract obligating the
agent to provide at least the same level of protection as is required by the
relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU
Data Protection Directive), Safe Harbor certification by the agent, or being
subject to another European Commission adequacy finding. Where the Companies
become aware that an agent is using or disclosing personal information in a
manner contrary to this Policy, the Companies will take reasonable steps to
prevent or stop the use or disclosure.
ACCESS AND CORRECTION:
Upon request, the Companies will grant individuals reasonable access to personal
information that it holds about them. In addition, the Companies will take
reasonable steps to permit individuals to correct, amend, or delete information
that is demonstrated to be inaccurate or incomplete.
SECURITY:
The Companies will take reasonable precautions to protect personal information
in its possession from loss, misuse and unauthorized access, disclosure,
alteration and destruction.
ENFORCEMENT:
The Companies will conduct compliance audits of its relevant privacy practices
to verify adherence to this Policy. Any employee that the Companies determine is
in violation of this policy will be subject to disciplinary action up to and
including termination of employment.
DISPUTE RESOLUTION:
Any questions or concerns regarding the use or disclosure of personal
information should be directed to the Companies' Privacy Office at the address
given below. The Companies will investigate and attempt to resolve complaints
and disputes regarding use and disclosure of personal information in accordance
with the principles contained in this Policy.
For complaints that cannot be resolved between the Companies and the
complainant, the Companies have agreed to participate in the DMA Safe Harbor
Program.
DMA safe Harbor Program
1615 L St NW, Ste, 1100
Washington, DC 20036-5624
safeharbor@the-dma.org
http://www.dmaresponsibility.org/safeharbor/consumers.shtml
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by the Companies to these Safe Harbor Principles may be limited (a) to
the extent required to respond to a legal or ethical obligation; and (b) to the
extent expressly permitted by an applicable law, rule or regulation.
CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to the following
person by mail as follows:
International Data Management
490 White Pond Drive
Akron, Ohio 44320
Attention: Data Privacy Office
P: 330.869.8500
F: 330.869.4027
CHANGES TO THIS SAFE HARBOR PRIVACY 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 the Company's web page
www.idmi.com
LINKS:
- US Department of Commerce Website at:
www.export.gov/safeharbor
provides further information and background about the Safe Harbor framework and
the Safe Harbor certified list.
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