In regards to personal information transferred from the European Economic Area ("EEA") to United States of America ("U.S."):
UniQuip, Plus Inc. ("UniQuip") respectfully values the privacy of their customers, business partners and employees and recognizes the necessity of appropriate protection and management of personal data provided. UniQuip, a U.S. based company, has made the decision to voluntarily participate in the Safe Harbor principles accessible to U.S. organizations within the European Commission's directive on data protection. Should there be any conflict between the Safe Harbor principles along with this Policy, the Safe Harbor principles will prevail. This Policy outlines the overall practices for implementing the requirements of Safe Harbor associated with personal data which can be transferred with the EEA into the U.S, including the sorts of information that is obtained and transferred, how it is used, and the choices individuals located in the EEA have regarding the utilization of, and power they have to correct that information.
For purpose of this Policy, these definitions shall apply: "Agent" means any other that collects and/or uses personal information supplied by UniQuip to operate tasks on the part of and in the operating instructions of UniQuip. Personal information signifies any information relating to an identified or identifiable person; an identifiable person is one who can be identified, directly or indirectly, particularly by reference to an identification number or one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Personal information does not include information that is anonymous or in circumstances where a person is not readily identifiable. "Sensitive personal information" implies personal data which reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health matters or sexual orientation.
4. Processing of EEA personal data
UniQuip may occasionally process EEA personal data about customers, business partners, employees and candidates for employment, including information recorded on various media along with electronic data.
UniQuip uses personal information concerning business partners and customers to offer them with information and services, and to assist UniQuip personnel better understand the needs and interests of those business partners and/or customers. Specifically, UniQuip uses information to aid customers and business partners complete an order or transaction, to facilitate communication, to deliver products/services, to bill for purchased products/services, and to provide ongoing service and support. Occasionally UniQuip personnel could use personal information to contact customers and business partners in order to complete surveys that are used for marketing and quality assurance purposes.
UniQuip may also share personal information with its service providers and suppliers with the sole purpose required to support the customers' business needs. Service providers and suppliers are requested to keep confidential personal information received from UniQuip and would not use it for any purpose except for it’s original intent.
UniQuip collects personal information concerning its employees (Human Resources Data) in connection with administration of the Human Resources programs and operations, and for purpose of communicating with its employees. These programs and functions occasionally includes compensation and benefit programs, employee development planning and review, performance appraisals, training, business travel expenses, tuition reimbursement, identification cards, access to UniQuip facilities and computer networks, employee profiles, internal employee directories, Human Resource record keeping, and other employment related purposes. Additionally, UniQuip collects and uses personal information to view candidates for job opportunities within UniQuip.
Human Resources data could possibly be shared with third party vendors with the exclusive purpose of enabling the vendor to provide service and/or support to UniQuip in association with these Human Resource programs and processes. Human Resource data is not shared with third parties for non-employment related purposes. Third parties receiving personal information are required to apply exactly the same degree of privacy protection as found in this Policy.
5. Privacy Principles
Where UniQuip collects personal information directly from individuals within the EEA, it will inform these individuals of it’s intent for the purposes and uses of personal information, the types of non-agent third parties to which UniQuip discloses that information, and the choices and means, if any, UniQuip offers individuals for limiting the utilization and disclosure of their personal information. Notice will be provided in clear and conspicuous language when people are first asked to supply personal information to UniQuip, or as soon as practicable thereafter, in any event before UniQuip uses the information for any purpose other than that for which it was originally collected.
UniQuip will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed into a non-agent third party, or (b) to be used for a purpose other than the point for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, UniQuip will give individuals the chance to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-agent third party or the use of the data for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. UniQuip will provide people with reasonable mechanisms to exercise their choices.
5.3. Onward Transfer to Agents
UniQuip will obtain assurances from its Agents that they will safeguard personal information according to this Policy. Examples of appropriate assurances that may be given by Agents include: a written contract obligating the Agent to offer not less than the same degree of protection as is needed by the relevant Safe Harbor principles, being susceptible to EU Data Protection Directive 95/46, Safe Harbor certification by the Agent, or becoming subject to another European Commission adequacy finding. Where UniQuip has knowledge that an Agent is utilizing or disclosing personal information in a manner contrary to this Policy, UniQuip will take reasonable steps to prevent or stop the utilization or disclosure.
Upon request, UniQuip will grant individuals reasonable entry to personal information that it holds about them. In addition, UniQuip will take reasonable steps to permit individuals to correct, amend, or delete information that is proved incorrect or incomplete.
UniQuip will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
5.6. Data Integrity
UniQuip will use personal information only in ways with the purposes that it was collected or subsequently authorized by the individual (see 5.2.). UniQuip will take reasonable steps to ensure that personal information is pertinent to its intended use, accurate, complete, and current.
6. Dispute Resolution
Any questions or concerns in connection with use or disclosure of personal information has to be directed to the Chief Ethics & Compliance Officer at the address given below. UniQuip will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles within this Policy.
With respect to any complaints with this Policy that can not be resolved through UniQuip's internal processes, UniQuip has decided to engage in the dispute resolution procedures on the Panel established by the EU Data Protection Authorities to resolve disputes pursuant to the Safe Harbor principles. In case UniQuip or such Authorities determines that UniQuip did not comply with this Policy, UniQuip will take appropriate steps to handle any adverse effects so to promote future compliance.
7. Targeting Minors
UniQuip will not knowingly collect personal identifiable information from persons under the age of (13) thirteen. If for reasons unknown conduct UniQuip determines that a particular person with respect to whom it has collected personal information is under thirteen, UniQuip will promptly delete or destroy that information.
8. Contact Information
Questions or comments with regards to this Policy should be submitted via our contuct us form.
9. Changes to this Policy