This Policy defines the commitment of Wesley Day and Company and its subsidiaries and affiliates (hereinafter referred as WDA) to protect the privacy of personal information that is collected or used in the course of conducting business. WDA will cause its subsidiaries and affiliates to establish and maintain business procedures that are consistent with this Policy.
A. We respect the privacy
rights of individuals.
WDA will respect the legal requirements that
exist regarding the privacy of personal information and is committed
to complying with all applicable law. WDA will, from time to
time, review its personal information collection, use, and disclosure
practices in order to assure compliance with laws and regulations.
B. We give notice of all
personal information collection.
WDA will give notice when personal
information is collected or when any collected information is later
to be provided to third parties. All notices will explain the
need for the information and describe how the information will
be used. Personal information will not be used to directly
market any products or services to identifiable persons unless
that possibility has been disclosed in advance and the opportunity
not to participate has been given.
C. We explain the consequences
of collecting and processing.
WDA will state the consequences of any
decision by individuals not to provide personal information
requested by WDA.
D. We get explicit consent
for sensitive information/opt-in.
WDA will maintain procedures to
assure that sensitive information is only collected with explicit
consent and is protected against improper use, consistent with
applicable law.
E. We process and distribute
information consistent with notice.
WDA will collect and use personal
information consistently with the notices that have been provided.
However, WDA may decide to remove identifiable features from
collected personal information and the resulting information may
then be used for statistical, historic, scientific, or other
purposes, consistent with applicable law.
F. We provide information
security.
WDA will maintain the security of personal information and
protect the integrity of such information with a commercially
reasonable degree of care.
G. We provide individuals
a way to access and correct their information.
WDA will maintain procedures
consistent with applicable law for individuals to gain access
to their collected personal information and, when appropriate,
correct any information that is inaccurate or incomplete, change
their individual consent level, or have their personal information
deleted.
H. We require others who
process WDA data to comply with the WDA policy.
WDA will contractually
require others who acquire or provide personal information
from or to WDA, including those engaged to provide support
services, at a minimum to comply with the principles and objectives
of this policy.
I. We provide a way to process
complaints.
WDA will publish the procedures for
responding to complaints, questions, and inquiries regarding its
established procedures for protecting personal information.
J. We will disclose personal
information when required by Law or court order.
WDA will, under certain
circumstances permitted or required by law or court order,
collect, use, and/or disclose personal information pursuant
to procedures that do not require giving notice or conducting
related activities (for example, in connection with law enforcement
investigations).
K. We will align our human
resource processes with the WDA policy.
WDA will align its human
resources processes, policies, practices, and guidelines (for
information that is collected or used relating to former, current,
or prospective employees) to comply with this policy.
L. We retain the flexibility
to change this policy.
WDA will, and reserves the right to, modify and
update this policy or its related business practices at any time.
WDA will NOT apply changes to this policy retroactively to
information WDA has previously collected.
