For purposes of this Policy, the following definitions shall apply: "Agent" means any third party that processes Personal Information provided by BVI to perform tasks on behalf of or at the instruction of BVI. "Personal Information" means any information or set of information that identifies or could be used by or on behalf of BVI to identify an individual. Personal Information does not include information that is encoded or anonymized. "Sensitive Personal Information" means Personal Information that reveals racial or ethnic origin, trade union membership, political opinions, religious beliefs (or beliefs of a similar nature), or that concern physical or mental health or condition, sexual life, the commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed. In addition, BVI will treat as sensitive Personal Information any Information received from a third party where that third party treats and identifies the information as sensitive.
This Policy applies to all Personal Information received by BVI in any format including electronic, paper or verbal. BVI collects, stores and processes Personal Information concerning customers, vendors current and Beaver-Visitec International Holdings, Inc. Data Protection and Privacy Shield Policyformer employees, as well as applicants for employment through its Internet websites, its intranet site, electronic mail and in offline formats. On a global basis, BVI will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Policy.
III. INFORMATION COLLECTION AND USE
Personal Information collected, stored and processed by BVI from employees and applicants for employment is maintained at its corporate offices in the United States or in the United Kingdom, or at other BVI facilities, consistent with local legislation. BVI collects Personal Information, such as name, contact information, taxpayer ID numbers, payroll information and employment histories for employment related purposes and legitimate human resource business reasons such as recruitment and staffing; payroll administration; absence monitoring; training and development; management planning; appraisal and promotion; production and publication of company address books and telephone and e-mail directories; production of employee Identity cards; monitoring the use of company resources; information to contact close relatives in case of emergency; filling employment positions; administration and operations of its benefit and compensation programs; meeting governmental reporting requirements; security, health and safety management; performance management; company network access; and authentication. BVI does not request or gather information regarding political opinions, religion, philosophy or sexual preference. To the extent BVI maintains information on trade union membership, medical health, race or ethnicity, BVI will protect, secure and process that Information in a manner consistent with this Policy and applicable law. Personal Information collected by BVI from prospective customers, consumers, vendors, business partners and others may be maintained at its corporate offices in the United States or in the United Kingdom, or at other BVI facilities, consistent with local legislation. BVI collects Personal Information, such as name, contact information, demographic information and payment information for legitimate business reasons such as customer service; product, warranty and claims administration; meeting governmental reporting and records requirements; maintenance of accurate accounts payable and receivable records; internal marketing research; safety and performance management; financial and sales data; and communications. BVI may also collect anonymous information concerning website users through the use of "cookies" or similar data collection technologies in order to provide better customer service. "Cookies" are small files that websites place on users' computers to identify the user and enhance the website experience. Company personnel periodically audit BVI’s commercial websites to determine what cookies are used on each. The cookies used are typically not intrusive and are not typically used to identify visitors personally. These passive information technologies enable BVI to provide better service to our customers, compile statistics, analyze trends and other wise administer and improve BVI’s websites. Information collected by these technologies cannot be used to identify a specific user without additional identifiable information and BVI will not connect additional identifiable information with information collected through such technologies as cookies. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies. Visitors can learn how to control or delete cookies used on BVI’s websites by visiting http://www.aboutcookies.org for detailed guidance. If visitors do suppress the website cookies, however, some areas of BVI websites may not function properly.
IV. INFORMATION SHARING
BVI may share Personal Information with third parties in a manner consistent with this Policy. BVI shares Personal Information with Agents who complete transactions or perform services on our behalf or for your benefit, such as payment processing, website hosting, marketing, analytics, payroll, or to verify personal information, such as mailing address. Under certain circumstances, BVI may be required to disclose Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements. BVI may need to disclose Personal Information to investigate claims, disputes or litigation, when otherwise required by law, or if BVI determines its disclosure is necessary to protect the health and safety of individuals, or to enforce legal rights or contractual commitments. BVI may also disclose Personal Information as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, including bankruptcy proceedings, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy or receivership.
V. PRIVACY PRINCIPLES
Where BVI collects Personal Information directly from individuals, it will inform them about the purposes for which it collects, stores and processes Personal Information about them, the types of non-Agent third parties to which BVI discloses that information, and the choices and means, if any, BVI offers 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 BVI, or as soon as practicable thereafter, and in any event before BVI uses the information for a purpose other than that for which it was originally collected.
BVI offers 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. To exercise this choice an individual may contact us using the contact information provided below indicating their opt-out request. For Sensitive Personal Information, BVI 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.
ACCOUNTABILITY FOR ONWARD TRANSFER
Where required by the Privacy Shield BVI will enter into contracts with its Agents that they will safeguard Personal Information consistent with the Principles and limiting their use of the information to the specified services provided on our behalf. Where BVI has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Policy, BVI will take reasonable steps to prevent or stop the use or disclosure. BVI holds it Agents accountable for maintaining the trust our employees and customers place in the company. Under certain circumstances, BVI may remain liable under the Principles if the third party Agents process Personal Information in a manner inconsistent with the Principles.
ACCESS AND CORRECTION
In some circumstances, individuals have the right to access the personal information that we maintain about them. Upon request, BVI will grant individuals reasonable access to Personal Information that it holds about them. In addition, BVI will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate, incomplete or has been processed in violation of the Principles. These access rights may not apply fully in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. Any consumers who would like to request access to, correction, amendment or deletion of their Personal Information, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. Any employees that desire to review or update their Personal Information can do so by contacting their local Human Resources Representative.
RECOURSE, ENFORCEMENT AND LIABILITY
BVI will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy and the Privacy Shield Principles. Any employee that BVI determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.
VI. COMPLAINTS AND DISPUTE RESOLUTION
BVI Privacy Inquiries Attention: Global Data Protection and Privacy Officer Beaver-Visitec International Holdings, Inc. 10 City Point 500 Totten Pond Road Waltham, MA 02451 Phone No. 781-906-7903
BVI has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. For purposes of enforcing compliance with the Privacy Shield, BVI is subject to the investigatory and enforcement authority of the US Federal Trade Commission. You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with BVI and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, please visit the U.S. Department of Commerce's website at https://www.privacyshield.gov/article?id=ANNEX-I-introduction. For complaints concerning the personal information of BVI employees BVI commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner, respectively, and comply with the advice given by the panel and/or Commissioner with regard to human resources data transferred from the EU and/or Switzerland, respectively, in the context of the employment relationship.
VII. THIRD PARTY LINKS
BVI websites may contain links to other "non-BVI" websites. BVI assumes no responsibility for the content or the privacy policies and practices on those websites. BVI encourages all users to read the privacy statements of those sites; their privacy practices may differ from those of BVI.
VIII. CONTACT INFORMATION