PAINE COMMUNICATIONS, INC.
Paine Communications, Inc. (“Paine”) is committed to protecting privacy. As part of this commitment Paine adheres to the highest standards of protection and has voluntarily agreed to comply with the Safe Harbor Privacy Principles consistent with the provisions of the European Community’s directive on data protection available to US organizations.
Web Site Users
Paine collects personally-identifiable information on certain areas of the web site (“Site”) when users register, request publications or other information and/or apply for jobs. The personally-identifiable information collected may consist of a unique access ID, company or school affiliations, titles, and contact information, such as names, mailing addresses, e-mail addresses, and telephone and fax numbers, and, for recruiting purposes, any other personally-identifiable information on a resume.
Paine uses personally-identifiable information to fulfill requests for information and to evaluate any job applications or other employment-related inquiries. We may keep any personally-identifiable information on file and use it for recruiting purposes. Paine also uses personally-identifiable information to perform statistical analyses of user behavior in order to measure interest in specific areas and articles posted on our Site. E-mail addresses provided at registration allow Paine to send e-mail to individuals based on the areas of interest that they indicate during the registration process.
Paine may use information stored on a user’s computer or other access device, also called “cookies,” to make sign-in, transactions, and other activities on the Site more efficient. These cookies will not contain any identifiable transaction data.
Paine will collect information about how its Site and any applications are used. This data may include a user’s domain name, language, type of browser and operating system, Internet service provider, Internet protocol (IP) address, the site or reference directing users to the Site, and the amount of time spent on the Site or using any application (collectively, “Usage Data”). Paine may monitor and use Usage Data in aggregated form to measure the Site’s performance and application activity and improve the Site’s design and functionality. Paine may also use Usage Data for security purposes or to verify transactions or other communications made in the applications.
LINKED SITES AND APPLICATIONS
Paine may provide links to third parties’ web sites or applications (“Linked Sites”) from the Site or any application. Linked Sites are not necessarily reviewed, controlled or examined by Paine. Paine is not responsible for the policies and practices of any Linked Site, or any additional links contained in them. Moreover, these links do not imply Paine’s endorsement of the Linked Sites or any company or service.
At no point during the collection of the above data does any third party have access to any user’s personally-identifiable information.
U.S.-EU and U.S.-Swiss Safe Harbor Privacy Principles
Paine complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Paine has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Paine’s certification, please visit http://www.export.gov/safeharbor/
Paine may perform software development or data management services for clients during which it may be given access to personally-identifiable information of European Union or Swiss residents employed by its client or its client customers. For purposes of this section, “personally-identifiable Information” or “information” means information that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual. “Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
At no point does Paine disclose any of this information to any third party. Paine affirms that its client’s data is the exclusive property of the client and that Paine will abide by the client’s directions in the treatment of this information.
Acting only as an agent for its clients, Paine is not required to provide persons whose personally-identifiable information is provided by Paine’s clients, an opportunity to choose or opt-out whether the personal information will be disclosed. However, Paine does not use customer data for any purpose incompatible with those authorized in its client agreements. Sensitive Personal Information, is not stored except as directed by the clients who own the data, and is not transferred to third parties except as authorized by client.
Paine maintains reasonable precautions to protect personally-identifiable information from loss, misuse and unauthorized disclosure, alteration or destruction. Only authorized users, bound by employee confidentiality agreements, have access to such stored data.
Paine collects only that data authorized by the client. Where Paine is directed by its clients to transfer data to a third party, Paine follows the data masking and confidentiality provisions agreed to by the client and third party.
Paine will correct, amend or delete any erroneous data if instructed to do so by its clients, subject to the principles of proportionality and reasonableness.
The above prohibitions against disclosure of personally-identifiable information are subject only to the following exceptions:
- Paine may disclose personally-identifiable information to third parties as required by court order or rule or other similar order or rule of any nation or state. Even in this circumstance, Paine will do everything in its power to disclose only the data required by applicable law or the authorities;
- Paine may disclose personally-identifiable information to third parties who deliver information for the purpose of performing such delivery.
Paine Communications, Inc.
Attn: Privacy Officer
316 N. Milwaukee Street
Milwaukee, WI 53202
Effective date: July 26, 2013