Ironguard Supplies is a trans-national business headquartered in the United States. Our management structure and business processes cross borders. Some of our technological systems and databases are shared between our US, European and other international offices. This means that our customer and employee data is transferred across borders.
Ironguard Supplies and each of its U.S. subsidiaries that may from time to time handle personal information collected from individuals located within European Union member countries and Switzerland comply with both the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, onward transfer and retention of personal information from European Union member countries and Switzerland. Ironguard Supplies has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles of:
§ Accountability for onward transfer
§ Data integrity and purpose limitation
§ Recourse, enforcement and liability
Ironguard Supplies is under the jurisdiction as well as the investigatory and enforcement powers of the US Federal Trade Commission for purposes of the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework.
This Policy applies to all information collected by Ironguard Supplies from which an individual can be identified (“Personal Information”). The Personal Information we collect includes the Employee Information described below as well as certain information including names, email addresses, mailing and billing addresses and telephone and fax numbers collected from customers, potential customers and end users of our products and services for sales, marketing, order fulfillment and order delivery purposes. Additionally, in our section on Online Information, we also discuss how we gather and use all information gathered online even if it is not Personal Information. Ironguard Supplies will not deviate from this Policy even if applicable national laws are less stringent than this Policy.
Excluding our Employee Information which is discussed below, we collect, process and use your Personal Information only as a part of our business relationship with you and your company, including contract and billing administration; product and service delivery; fulfilling our business obligations to our customers and resellers; communicating with customers and potential customers about marketing and technical information concerning our products and services; notifying our customers and potential customers regarding product launches and important events related to Ironguard Supplies; and other related business activities of which you are informed of at the time your Personal Information is collected or as soon thereafter as practical. Ironguard Supplies only collects personally identifiable information about individuals when such individuals specifically provide such information to us on a voluntary basis or while requesting information on our products or services. We may disclose Personal Information to our agents, resellers, and business partners or to protect and defend the rights or property of Ironguard Supplies. Ironguard Supplies must reply to lawful requests from public authorities, including to meet national security or law enforcement requirements, for disclosure of Personal Information.
Ironguard Supplies does not sell, lease, or rent Personal Information to third parties.
In general, you may visit our Websites without providing any Personal Information. However, you may choose to provide us with Personal Information by completing online forms. At the point of collection, we will inform you of how your Personal Information will be used; apart from these uses, Ironguard Supplies will only use your Personal Information in accordance with the terms of this Policy.
Cookies are small files that a site transfers to your computer’s hard drive through your web browser (if you allow) that enables it to recognize your browser and capture and remember certain information. A cookie cannot read data off of your hard drive or read cookie files created by other sites. Cookies may do things like allow you to navigate faster through the site, remember your preferences and passwords, and generally improve the user experience. You can turn off the ability to receive cookies by adjusting your browser settings — please note that if you do so, this may affect the functionality of the website and the information you can access through it.
As part of AdWords remarketing, we use the Google Analytics cookie and the DoubleClick cookie together to inform, optimize, and serve ads based on someone’s past visits to our website. Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Preferences Manager.
Google has additional information available about their Remarketing Privacy Guidelines, Policies, and Restrictions.
We collect Employee information from prospective and present Employees only for legitimate business purposes, including (1) the management and operations of our company, its functions and activities, (2) Employee communications, including Employee surveys, (3) maintaining a global directory, (4) carrying out obligations under employment contracts and employment, tax and benefits laws, and in connection with other working relationships or arrangements, (5) development and training programs, (6) recruiting and hiring job applicants, (7) assessing qualifications and performance, (8) performing background checks and verifying references, (9) managing Employee performance, (10) determining Employee compensation or payment, (11) managing the Employee termination process, and (12) other general human resources purposes. Our European Union Employees at the time of their employment are notified in detail how their Personal Information will be used. Employee information on health, performance evaluations, and disciplinary actions and other sensitive Employee matters, whether it is stored manually or electronically, is accessible by other Ironguard Supplies Employees only if necessary with respect to legitimate human resource functions or issues. Ironguard Supplies will obtain affirmative consent from an Employee before using such Employee’s Personal Information for any purpose other than described above. Employees may decline to provide this consent, and Employees may withdraw their consent at any time.
For legitimate human resources purposes, Employees may choose to voluntarily disclose Personal Information about family members. If our Employees choose to do this, their family member’s Personal Information shall be treated, for the purposes of this Policy, the same as an Employee’s Personal Information. Employee Personal Information is never sold, leased, or rented to any third party. Employee Personal Information will never be disclosed to third parties except as follows: (1) to those retained by Ironguard Supplies as agents for the purposes set forth in the paragraph above, (2) where required pursuant to an applicable law, governmental or judicial order, law or regulation, or to protect the rights or property of Ironguard Supplies, (3) where authorized in writing by the Employee, and (4) where the Employee voluntarily provides Personal Information and the context makes it clear that such information will be provided to a third party.
Where personal data is transferred from the EU to the US in the context of the employment relationship, we will cooperate in investigations by and to comply with the advice of the competent EU Authorities.
We will always give you an opportunity to choose opt-out before your Personal Information is (1) disclosed to a third party (other than an Ironguard Supplies agent doing work at our direction), or (2) to be used for a purpose that is materially different than that for which it was originally collected or subsequently authorized by you. Although we do not ever anticipate providing sensitive Personal Information, such as Employee health information, to a non-agent third party or using it for a purpose other than that for which it was collected, we will never do so without first allowing the individual involved to affirmatively and expressly consent (opt-in) to such transfer or use. The only exception to this choice for both sensitive and non-sensitive Personal Information would be where we are required to disclose your Personal Information pursuant to governmental or judicial order, law or regulation to meet national security or law enforcement requirements.
At a minimum, you will always be able to opt-out from receiving marketing materials from Ironguard Supplies. If we determine that applicable national law requires that more stringent requirements (opt-in) be applied before you receive marketing material or other communications from us, we will implement the same.
Accountability for Onward Transfer
We will not transfer Personal Information originating in the EU to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your Personal Information as required by the Principles of the EU-US Privacy Shield Framework or the Swiss-US Privacy Shield Framework. We will only transfer data to our agents, resellers or third party service providers (such as accountants, attorneys, consultants, and other service providers) who need the information in order to provide services to or perform activities on behalf of Ironguard Supplies, including in connection with the delivery of services or products, Ironguard Supplies’ management, administration, or legal responsibilities. We acknowledge our liability for such data transfers to third parties.
To protect Personal Information collected and stored by Ironguard Supplies, we have in place reasonable and appropriate technical and operational security measures to prevent Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Data Integrity and Purpose Limitation
We will only collect and retain Personal Information which is relevant to the purposes for which the information is collected, and we will not use it in a way that is incompatible with such purposes unless such use has been subsequently authorized by you. We will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete, and current. We may occasionally contact you to determine that your data is still accurate and current.
If you wish to access, amend, or confirm that Ironguard Supplies has personal data relating to you, or if you wish to correct or delete your Personal Information if it is inaccurate, please notify us at: firstname.lastname@example.org. We will respond to your request within a reasonable time.
Employees may review their personnel files and any Personal Information concerning them upon request by emailing email@example.com.
Recourse, Enforcement and Liability
Since we are committed to protecting your privacy as set forth in this Policy, if you think we are not in compliance with our Policy, or if you have any question or if you wish to take any other action concerning this Policy or your Personal Information, we encourage you to contact us at: firstname.lastname@example.org. We will investigate your complaint, take appropriate action and report back to you within 45 days.
If the Personal Information in question was transferred from the EU to the United States, and you are not satisfied with our response, have further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association (AAA)’s Independent Conflict Dispute Resolution ICDR/AAA Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit http://info.adr.org/safeharbor for more information or to file a complaint.
Additionally, with respect to complaints concerning human resources data that is transferred from the EU in the context of the employment relationship, we have agreed to participate in the dispute resolution procedures of the EU Data Protection Authorities. Ironguard Supplies will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints concerning human resources data that is transferred from the EU to the United States brought under Privacy Shield. For complaints involving human resources data transferred from Switzerland in the context of the employment relationship, we commit to cooperate with Swiss Federal Data Protection and Information Commissioner (“FDPIC”) and comply with the advice given by the FDPIC. Complaints regarding processing of human resources data pertaining to EU and Swiss citizens may be reported by the individual to the relevant Data Protection Authority.
These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.
Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.
Right to Change Policy
In general, changes will be made to this Policy to address new or modified laws, changes to EU-US Privacy Shield Framework or the Swiss-US Privacy Shield Framework, or new or modified business procedures. However, we reserve the right to amend this Policy at any time. Appropriate notice will be given concerning such amendments.
Effective: July 1, 2020.