SIRVA respects
your privacy, and this Privacy Policy is intended to inform you of how we
protect your private, personal information.
One Policy
SIRVA has one global Privacy
Policy for consumers applying to the entire SIRVA family of companies
("SIRVA"). SIRVA is committed
to complying with all local and worldwide privacy laws.
Information Covered by this Policy
Our Policy covers all non-public,
personal information received by us that may be used to identify you
("Personal Information").
General Data Protection Regulation Information
When we are acting at the direction of a corporate client to
provide services to you, then the client is responsible as the Data Controller
for telling us how your Personal Information should be used and processed. Under the European Union’s General Data
Protection Regulation, SIRVA and its family of companies are Data Processors
who receive Personal Information and instructions on how to process that
Personal Information from the Data Controllers. Where we act as a Data Controller (i.e., where we independently determine
how any Personal Information is processed), then we manage your Personal
Information according to what you have consented to and the terms of this
policy.
How We Obtain Personal Information
SIRVA relies upon many sources of
information to understand and meet your needs. We may receive Personal Information
about you from:
· You directly, when you complete an application or when you visit
us in person, over the phone, through the mail or through our websites;
· Your transactions with any of the companies in the SIRVA family;
· Consumer reporting agencies;
· Mortgage, Title, appraisal or other companies connected with a
financial product or service involved in the sale or purchase of your home;
· Your employer;
· Anyone who you have authorized to provide information; and
· Other sources, in connection with providing you a financial
product or service.
Regardless of its source, SIRVA
will not process Personal Information without your consent.
Although we do not receive Personal
Information from your browser, we do monitor and store certain types of
information about visitors to our website--namely, the type of browser used, the
user’s country, whether they were referred to us by a search engine, which of
our pages they visit, and how those pages perform on the user’s computer. This helps SIRVA make decisions on how to
better design, streamline, and improve performance on our websites. If you do not want this information monitored,
you may turn off JavaScript. Please be
advised, however, that the websites may not provide full functionality if those
settings are turned off.
We also use “cookie” technology
to improve your experience on our site. For details on our cookie policy, please see our website.
We do not knowingly collect
Personal Information from children and will destroy such information if it is
disclosed to us without proper parental consent.
Information Sharing within the SIRVA Family of Companies
To provide you with the full
range of financial, relocation, and moving services you may need, SIRVA takes
an integrated approach to the services we provide. In order to be able to
provide a full range of services for your needs and make recommendations about
a variety of the services offered by SIRVA, we may share Personal Information
among the SIRVA family of companies.
Information Sharing with non-SIRVA Family Companies
Depending on the type of services
you are to receive, SIRVA may work with and provide your information to companies
or persons outside of the SIRVA family to provide those services to you. For example, SIRVA may share personal
information to:
· service and support our operations generally and to support your
account and services that we provide to you, including proposed or actual
financing, securitization, secondary market sale, or similar transactions;
· process or administer a transaction or product in connection with
a product or transaction that you have requested;
· data storage and processing;
· those you have authorized us to disclose the information;
· other suppliers with whom we have agreements to offer services
to you through or with SIRVA; or
· other suppliers with which we jointly market or provide products
or services.
We may also share your Personal
Information with these other organizations outside of the SIRVA family when required
by law. For example, we may share personal information to:
· protect against fraud;
· respond to a subpoena or summons; or
· respond to law enforcement or regulatory authorities.
We will not
disclose your Personal Information to anyone outside of SIRVA unless you have
authorized us to do so or as otherwise indicated in this Policy or as required
by law.
We maintain
agreements with our external suppliers limiting the use of your Personal
Information only for the purposes you have intended in providing the
information. These suppliers are bound to uphold our standards and procedures
regarding privacy under the terms of our agreements with them.
Access & Choice
SIRVA provides you with a
reasonable opportunity to access your own Personal Information, to correct that
information if inaccurate, or to have it deleted as appropriate--subject to the
exceptions stated below. Reasonable access means, for example, that requests
for access are made during normal business hours; that you provide requested
identification; and that requests are not excessive in number. If, at any time,
SIRVA denies you access to any Personal Information, we will provide you with
reasons for denying access and information about how you may make further
inquiries. For instance, SIRVA reserves the right to deny access to information
related to investigations or potential or actual litigation where the burden or
expense of providing access would be disproportionate to the risks to the
individual's privacy, or where the rights of other individuals would be
violated. In order to update your information, please send your request by
electronic mail to privacy.administrator@sirva.com, by facsimile to the number (216) 606-7654, or by telephone to
the number (216) 606-7912.
You have the right to opt out of
any use of your Personal Information at any time via the contact information
above. If you opt out of this policy or
otherwise decline to provide Personal Information, it may affect your receipt
of services.
Data Integrity & Security
SIRVA will make every reasonable
effort to keep Personal Information accurate while we are using that
information to serve you. SIRVA appreciates your cooperation in maintaining
complete and up-to-date Personal Information and will facilitate your efforts
in this regard. SIRVA retains Personal Information for as long as we have
determined it is needed for the purposes for which it was received or as
required by contractual, record keeping, or other legal requirements.
We limit access to Personal Information
about you to those employees who need to know that information to provide
products and services to you. We do not sell your Personal Information.
We maintain physical, electronic,
and procedural safeguards to protect your Personal Information. We regularly
assess security standards and procedures to protect against unauthorized access
to Personal Information.
We store your Personal
Information on servers that may be located in various countries, but always in
compliance with this policy and all applicable data privacy laws and
regulations.
You should always safeguard your
own Personal Information by protecting passwords used to access a SIRVA system
and by safely disposing of records and reports no longer needed.
SIRVA will notify and work with
regulatory and/or law enforcement officials as required by law to address any
issues or security breaches where they arise.
Enforcement
A. Verification
Employee training and internal procedures are in place to allow SIRVA to ensure
compliance with its Privacy Policy. SIRVA provides for regular internal
compliance reviews of its privacy practices, and a SIRVA has a Data Protection Office
that is responsible for privacy implementation and compliance. For assistance
with privacy concerns, you may send comments by electronic mail to privacy.administrator@sirva.com, by facsimile to the number (216) 606-7654, or by telephone at
(216) 606-7912.
B. Dispute Resolution
SIRVA recognizes the importance of providing you the opportunity to address and
resolve complaints about the processing of your Personal Information.
Therefore, in addition to any legal remedies that may be available, if you make
a complaint with us about the processing of your Personal Information and it is
not resolved to your satisfaction internally at SIRVA, you may also file a
complaint with the American Arbitration Association ("AAA") at the
AAA website, located here, or seek its independent alternative dispute resolution services. The American Arbitration Association
("AAA") is also located at the following address:
225 North
Michigan Avenue, Suite 2527
Chicago,
Illinois 60601-7601 USA
The AAA can be reached by telephone
at (312) 616-6560 or by facsimile at (312) 819-0404.