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, Acorio or to which Acorio discloses personal information for use on Acorio’s behalf.
“Acorio” means Acorio, LLC, its predecessors, successors, subsidiaries, 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 Acorio 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, age, ethnic origin, political opinions, wages or salaries, employment benefits with your current or past employer, 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, Acorio will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
NOTICE: Notice will be provided in clear and conspicuous language if and when individuals are asked to provide personal information to Acorio, or as soon as practicable thereafter, and in any event, before Acorio uses or discloses the information for a purpose other than that for which it was originally collected.
CHOICE: Acorio will offer 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, Acorio 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.
Acorio will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: Acorio will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Acorio will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: Acorio will obtain assurances from its 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 stated in this Policy. Where Acorio has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Acorio will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request, Acorio will grant individuals reasonable access to personal information that it holds about them. In addition, Acorio will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: Acorio will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: Acorio will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Acorio 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 Acorio Privacy Office at the address given below. Acorio 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.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by Acorio to these 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.
Questions or comments regarding this Policy should be submitted to the Acorio Privacy Office by mail to:
Acorio Privacy Office
260 Franklin St.
Floor 3 Boston, MA 02110
Or by e-mail to the Acorio Privacy Office (firstname.lastname@example.org)
EFFECTIVE DATE: January 1, 2017