I. Participation in Privacy Shield and Relevant Entities
- UniGroup Worldwide, Inc., dba UniGroup Moving (“UniGroup Worldwide”) and
- Sterling Relocation Americas, Inc. (“Sterling Relocation”) (collectively, “we” or “us”).
We hereby commit to subject to the Privacy Shield Framework Principles all Personal Data we receive from the EU, EEA and Switzerland in reliance on Privacy Shield. We comply with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information transferred from the EU, the E.E.A. and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this 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 . The list of entities who are Privacy Shield certified can be found at https://www.privacyshield.gov/list.
II. Personal Data Collected
In the course of providing a product or service to you, or in interactions with you as a potential customer, including but not limited to interaction through the websites related to the entities listed in section 1, we will collect personal data. The data types collected constitute:
a. Personal contact information such as name, street and email address, phone number or other personal identifiers that you provide to us for contact (e.g., social media identifiers);
b. Financial information, such as credit card or other bank account data;
c. When providing moving services, your origin address and destination address, details about the nature of the goods being shipped, including any photographic, video and/or other digital image capture of those goods, and the names and contact information for other persons involved in the shipment or authorized to provide direction on your behalf;
d. When providing relocation services, the same information as in (c), as well as information included on passports and customs documentation, and potentially, depending on services chosen, information included on visa or other immigration documentation, financial and other personal information contained in home loans or house deeds or rental agreements, languages spoken, and potentially including information pertaining to medical or health conditions, racial or ethnic origin, sexual orientation, and religious or philosophical beliefs.
III. Purposes for which Personal Data is Collected and Used
We limit our collection of Personal Information to that which is necessary for its intended purpose. We may use Personal Data to do the following:
Conduct Surveys. From time to time, we may use survey forms to better understand our customers’ needs, to evaluate our services, and to create products and services that respond to their interests. Customers may decline to participate in these surveys. We will not disclose survey response information outside of our controlled group of related entities, other than to our survey vendor(s) who assist us in collecting and analyzing such information or to other authorized service providers, solely for the purpose of improving our products and services.
Comply With Legal Processes. There are situations where we may disclose to third parties the Personal Data we collect as required by lawful requests from public authorities or to meet law enforcement requirements. This may include disclosure to government entities, courts or other entities, such as in response to subpoenas or other legal or regulatory processes, or to protect against fraud.
Other Business Interests. We may also combine your Personal Data with other consumers’ Personal Data or other publicly available information to help us satisfy our legitimate business interests, such as performing trend analysis or market studies; identify consumer preferences or interests; set prices; perform necessary Information Technology environment testing, or computer programing in test or production environments; perform billing functions; establish credit; or comply with government regulations. We may also share anonymized data, such as statistical or demographic information in aggregate form, with third parties for research or marketing purposes. However, this anonymized data will not contain any of your individually identifiable Personal Data.
Credit Reporting Agencies. We may report information about your account(s) to credit bureaus and/or consumer reporting agencies. Late payments, missed payments, or other defaults on your account(s) may be reflected in your credit report and/or consumer report and may affect your ability to obtain credit.
IV. Access, Opt-Out, Complaints and Dispute Resolution
We will provide you with a reasonable opportunity to confirm we are processing Personal Data regarding you, request we communicate your Personal Data to you to verify its accuracy and that it is being processed lawfully, and to have your Personal Data corrected, amended or deleted when inaccurate or processed in violation of the Principles. Subject to relevant local legal requirements, (a) any such requests must be reasonable in number and scope; (b) we reserve the right to deny access to information where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, where the rights of other individuals may be violated, when it may interfere with the execution or enforcement of the law or with private causes of action, including the prevention, investigation or detection of offenses, or when disclosure would breach a legal or other professional privilege or obligation. If you wish to make a request to access your Personal Data, or have any questions or concerns about our policies or practices, please contact us at email@example.com or (US + 1) 800-637-2154.
Subject to the limitations in the Privacy Shield Framework, you have the right to choose (opt out) whether your Personal Data is: (a) to be disclosed to a third party, or (b) to be used for a purposes other than the purpose for which it was originally collected of subsequently authorized. Individuals may send opt-out requests to the above contact address and phone number. By providing us with Personal Data and/or by using our services, individuals have opted to authorize us to use the Personal Data for the purposes it was intended by for no other purpose. Prior to disclosing Personal Data for any other purpose, we will notify you of such disclosure and allow you the choice to opt-out of such disclosure.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our US-based third party dispute resolution provider (free of charge) at: https://feedback-form.truste.com/watchdog/request
Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. Additional information regarding arbitration, including the circumstances when it may be invoked, can be found at Annex 1 of the Privacy Shield Framework, at the following link: https://www.privacyshield.gov/article?id=ANNEX-I-introduction
The Federal Trade Commission has jurisdiction over our compliance with Privacy Shield.
V. Onward Transfer
Any third party vendor or provider to which we provide Personal Data shall subscribe to the Principles or otherwise provide adequate protection. We shall remain liable under the Principles if our third party data processing agent processes your Personal Data in a manner inconsistent with the Principles, unless we prove we are not responsible for the event giving rise to the damage.