Privacy Policy

Privacy Policy - Non Human Resources Data

Privacy Policy: Non-Human Resources Data       

 

Purpose and Scope

Due to the global nature of the mobility industry and Dwellworks’ business operations, the transfer of personal data across national borders may occur.  Dwellworks respects and strives to protect the privacy of its associates, supply chain partners and transferees.  Personally, identifiable and sensitive data that identifies or describes a living person (hereinafter “Personal Data”) which is collected, used or disclosed by or on behalf of Dwellworks is protected in accordance with the laws of the countries in which Dwellworks operates.  This Privacy Policy governs the way Dwellworks manages and processes Personal Data collected in the process of delivering relocation services in the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) that is subsequently transferred to the United States as well as Personal Data that collected in the process of delivering relocation services elsewhere in the world including within the United States.This Policy applies to Personal Data received by Dwellworks in any format, including electronic, paper or verbal. 

 

Principles

Types of Data Collected

Personal Data collected is limited to information necessary to conduct business.  Personal Data collected includes but is not limited to: name, address, government identification number (i.e., social security number, national identification number, tax payer identification number, passport information, driver's license, date of birth, phone number, email address, OFAC information, financial information and bank account information.

Notice

Dwellworks will inform individuals about the purposes for which it collects and uses Personal Data, the types of third parties or agencies to which it discloses such information, and the choices which Dwellworks offers to limit the use and disclosure of Personal Data. The sharing of Personal Data by Dwellworks with its network of third party suppliers of relocation related services is necessary for the purpose of providing relocation services to its customers and their transferring employees. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data or as soon as practical thereafter.  If Dwellworks receives Personal Data from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such Personal Data in accordance with the notices provided by such entities.

Choice

Dwellworks offers individuals the opportunity to opt out of disclosing their Personal Data to a third party or for a purpose other than which it was originally collected or subsequently authorized.  For sensitive data, Dwellworks offers individuals the opportunity to affirmatively and explicitly consent to the disclosure of the information to a third party or the use of the information for a purpose other than which it was originally collected or subsequently authorized.

Onward Transfer

Dwellworks will only transfer Personal Data to a service provider, vendor or other third party acting as a processer of Personal Data for Dwellworks where that party has provided assurances that it provides at least the same level of privacy protection as is required by this Policy.  Where Dwellworks becomes aware that a party is using or disclosing Personal Data in a manner contrary to this Policy, Dwellworks will take reasonable and appropriate steps to prevent or stop the use or disclosure of that Personal Data. On occasion, Dwellworks may be required to share your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security

Dwellworks takes reasonable steps to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.  These precautions include but are not limited to password protections for online systems and restricting access to Personal Data to the Human Resources Department (“HR”) for associates or the legal department or their relocation consultant for transferees.  Individuals who have access to Personal Data are aware of their responsibilities to protect the security, confidentiality and integrity of the information.

Access

Associates and transferees can access their Personal Data and can correct or amend it if it is inaccurate or incomplete.  Dwellworks reserves the right to deny or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to the individual’s privacy.  Any Dwellworks associate or transferee that wants to review or update their Personal Data can do so by contacting HR.

Data Integrity

Dwellworks will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual.  Dwellworks will take reasonable steps to ensure that Personal Data is reliable, complete, accurate and current.  All associates and transferees are asked to inform HR or their consultant respectively immediately in the event of changes in Personal Data.

Enforcement, Verification and Dispute Resolution

Associates and supply chain partners who violate data privacy rules may be subject to potential civil and/or criminal liability.  Dwellworks conducts periodic reviews of its privacy practices to verify adherence to this Policy and the Privacy Shield principles.  This Policy may be updated occasionally to reflect changes to Dwellworks’ privacy practices.

Transferees, associates and others whose Personal Data is handled by Dwellworks should contact Dwellworks if there is reason to believe that the security of their Personal Data has been compromised.  Dwellworks will investigate and attempt to resolve complaints regarding use and disclosure of Personal Data.  For any complaints that cannot be resolved with Dwellworks directly, Dwellworks has selected the ICDR/AAA as our Independent Recourse Mechanism in relation to such unresolved complaints (as further described in the Privacy Shield Principles). The link to the ICDR/AAA for making complaints is as follows: http://go.adr.org/privacyshield.html.

We will be providing, at no cost to you, the services of the ICDR/AAA by which your complaint or dispute will be investigated and expeditiously resolved.

A binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Dwellworks is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Contact Us

Contact information: Hank Roth, Dwellworks’ Chief Privacy Officer can be reached for complaints, questions or information regarding our Privacy Policy and Privacy Shield participation.

  • Phone – 216 682-4270
  • Email – roth@dwellworks.com
  • Mail – Dwellworks, 1317 Euclid Avenue, Cleveland, Ohio 44121

We will respond to your complaints or inquiries within a reasonable time but in no event later than 45 days.

 

Declarations Regarding the Privacy Shield

Before sharing Personal Data concerning a European Union resident with a third party, Dwellworks will verify that the third party holds Personal Data in a manner consistent with this Policy, and certifies compliance with the European Union’s data protection laws and the Privacy Shield requirements.

Dwellworks complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Dwellworks has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Dwellworks participation in the Privacy Shield applies to all personal data that is received from the European Union, European Economic Area. Dwellworks will comply with the Privacy Shield Principles in respect of such personal data.

Dwellworks’ accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Dwellworks remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Dwellworks proves that it is not responsible for the event giving rise to the damage.