Midland Information Resources Privacy Policy

Effective Date: July 6, 2015

Latest Revision: July 12, 2016

Midland Information Resources respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does Midland Information Resources strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy Statement (the “Policy”) sets forth the privacy principles Midland Information Resources follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway).

U.S. – E.U. SAFE HARBOR

Consistent with its commitment to protect personal privacy, Midland Information Resources complies with the U.S. – E.U. Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union member countries. Midland Information Resources 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 Midland Information Resources’ certification, please visit http://www.export.gov/safeharbor/.

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the "U.S.-EU Safe Harbor"). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection.

SCOPE

This Safe Harbor Privacy Policy Statement (the “Policy”) applies to all personal information received by Midland Information Resources in the United States from the EEA, in any format, including electronic, paper or verbal. This Policy describes how Midland Information Resources collects and uses the personal information you provide. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

The self-assessed certification covers our collection, use and disclosure of information we collect through our service Elanders Americas Customer Portal and Online Ordering Site. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Midland Information Resources.

COLLECTION AND USE

COLLECTION: We collect the following kinds of personal information from our Clients:

Contact Information such as name, email address, mailing address, phone number
Billing Information such as credit card number, and billing address

We may also collect the following information from some of our Clients:

Information about your business such as company name, company size, business type
Product information

DATA SUPPLEMENTATION: We obtain address information about you from third party sources, such as the US Postal Service, to verify your address is valid and complies with addressing standards.

USE: We use this information to:

Fulfill your order
Send you an order confirmation
Respond to customer service requests
Administer your account

SHARING: We will share your personal information with third parties only in the ways that are described in this Policy.

SERVICE PROVIDERS: We may provide your personal information to companies that provide services to help us with our business activities such as processing your credit card information. These companies are authorized to use your personal information only as necessary to provide these services to us. For our data processor services Midland Information Resources collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes.

TECHNOLOGIES: We use technologies such as cookies, tags, scripts; our partners, affiliates, analytics or service providers use cookies, beacons, scripts, tags and Local Storage. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

COOKIES: We use Site Management and Analytics cookies on the site. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.

LOCAL STORAGE: Third parties with whom we partner use Local Storage, such as HTML5, to provide certain features on our website based upon your web browsing activity. HTML5 is also used to collect and store information. Various browsers may offer their own management tools for removing HTML5.

LOG FILES: As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Midland Information Resources or to which Midland Information Resources discloses personal information for use on Midland Information Resources’ behalf.

“Midland Information Resources” means Midland Information Resources, its divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of Midland Information Resources to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Midland Information Resources will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE: Where Midland Information Resources collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which Midland Information Resources discloses that information, the choices and means, if any, Midland Information Resources offers individuals for limiting the use and disclosure of personal information about them, and how to contact Midland Information Resources. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Midland Information Resources, or as soon as practicable thereafter, and in any event before Midland Information Resources uses or discloses the information for a purpose other than that for which it was originally collected.

Where Midland Information Resources receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: Midland Information Resources collects information for our clients; if you are a customer of one of our clients and would no longer like to be contacted by a client that uses our service, please contact that client directly.

Midland Information Resources offers individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Midland Information Resources will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Midland Information Resources will provide individuals with reasonable mechanisms to exercise their choices when applicable.

DATA INTEGRITY: Midland Information Resources will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Midland Information Resources will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: Midland Information Resources may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients. We obtain assurances from our agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission (e.g., companies located in Canada). Where Midland Information Resources has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Midland Information Resources will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: If you wish to request access, or deletion of your personal information please contact us at the email address available below. Midland Information Resources will respond to your request within a reasonable timeframe and take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

ACCESS TO DATA CONTROLLED BY OUR CLIENTS: Midland Information Resources has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Midland Information Resources’ Client (the data controller). If the Client requests Midland Information Resources to remove the data, we will respond to their request within a reasonable timeframe.

DATA RETENTION: Midland Information Resources will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. We will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

SECURITY: Midland Information Resources will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. We follow generally accepted standards to protect the personal information submitted to us during transmission and upon receipt.

ENFORCEMENT: Midland Information Resources will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Midland Information Resources determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Midland Information Resources IT Department at the address given below. Midland Information Resources will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between Midland Information Resources and the complainant, Midland Information Resources has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

for disputes involving employment-related personal information received by Midland Information Resources from the EEA, Midland Information Resources has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
for disputes involving all other personal information received by Midland Information Resources from the EEA, Midland Information Resources has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities (DPA);
Individuals who submit a question or concern to Midland Information Resources and who do not receive acknowledgment from Midland Information Resources of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the European data protection authorities by one of the contact methods listed below. Inquiries by mail or fax should identify Midland Information Resources as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether DPA may share the details of the inquiry with Midland Information Resources.
1. Online http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
2. Mail: European Commission
  B-1049 Brussels
  Belgium
3. Tel.: +32 2 29 68750
4. Fax: +32 2 29 63891

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Midland Information Resources to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

We may also disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the Midland Information Resources IT Department by mail to:

IT Department
Midland Information Resources
5440 Corporate Park Drive
Davenport, IA 52807

Or by e-mail to the Midland Information Resources IT Department

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be updated to reflect changes to our information practices and to remain consistent with the requirements of the Safe Harbor Principles. If we make any material changes we will notify you by means of a notice posted on the Midland Information Resources online ordering sites (oost2.demo.elandersamericas.com and customerportal.elandersamericas.com) prior to the change becoming effective and for 60 days. We encourage you to periodically review this page for the latest information on our privacy practices.