Information Collection and Use
The information we collect is provided directly to us by our clients, the client’s employees, and the client’s perspective employees. We collect only the information required to provide the Services that our clients have formally engaged with us to perform, mainly employee relocation management. As an employee relocation company, we need certain personal information to effectively deliver Services to each employee we help and manage the relocation benefits guaranteed to them from their company’s relocation policy.
We may also obtain personal information from individuals who choose to provide us with this type of information (name, address, email, and phone number(s) in order to be contacted regarding services we provide.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for NRI to process both types of personal data, but it must be explicitly given to NRI or from our client. Where we are asking you for sensitive personal data, we will always tell you why and how the information will be used. You may withdraw consent at any time by contacting email@example.com.
Legal Disclaimer – we may also disclose your personal information for the following reasons:
- As required by law, such as to comply with a subpoena, 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.
- If NRI is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
- To any other third party with your prior consent to do so.
- We may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
User Access and Rights Under GDPR
If your personal information changes, you may correct, update, amend, remove, or ask to have it removed by either making the change on your user account settings page, contacting our Customer Support at firstname.lastname@example.org or by contacting us by telephone or postal mail at the contact information listed below.
Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. If you no longer desire our service, please contact us directly. We will respond to your request within a reasonable timeframe. We will retain your information for as long as your account is active and/or as needed to provide the Services we have been contracted to provide. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
NRI acknowledges that EU individuals have the following rights under the General Data Protection Regulation (GDPR):
- Right to be informed
- Right to access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to data portability
- Right to object
- The right in relation to automated decision making and profiling
An EU individual, who seeks to implement these above GDPR rights, should direct their query to email@example.com. If requested to, we will respond within the GDPR timeframe of 30 days unless an exception occurs and we will notify you the data subject immediately for an extension.
EU individuals may also have the right to submit a GDPR complaint for their local data protection authority. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
How Can I Find Out All the Personal Data That the Company Holds about Me?
At your request, NRI can confirm what information we hold about you and how it is processed. If NRI does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or company that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the Data Protection Officer.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of NRI or a third party, information about those interests.
- The categories of personal data collected, stored, and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict, or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What Forms of ID Will I Need to Provide in Order to Access This?
NRI accepts the following valid forms of identification (2 forms required) when information on your personal data is requested. Please contact firstname.lastname@example.org for further assistance.
- Driver’s License
- Birth Certificate
- Utility Bill
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at email@example.com.
We will provide an individual an explicit opt-in choice before we share data with third parties other than our agents, or before we use it for a purpose other than, which it was originally collected or subsequently authorized. To limit and/or stop the use and disclosure of your personal data, you can contact us at firstname.lastname@example.org.
The security of personal information is very important to NRI. NRI uses industry best practices, physical, procedural and technical, to protect the security of personal information shared with us. Our employees are regularly trained to protect information using our information security and privacy policies and practices. NRI restricts access to information to only authorized employees and uses access and transmission controls such as encryption, firewalls and authentication tools to further protect information.
In addition, any third-party suppliers we utilize on your behalf are contractually obligated to notify us of any information breach concerning our clients and customers pursuant to applicable U.S. and international data breach laws. Any questions regarding our site security at our sites can contact email@example.com.
Tracking Your Usage
The NRI website and portals use “cookies” to track and record session information for your convenience. Cookies are bits of information that are automatically stored on your computer. Most cookies expire after a period of time and you can delete cookie files at any time. Cookies do not contain any personally identifiable information such as your name, address, or any financial information. You can set your browser preferences to disable cookies, however if you do so, you will not be able to utilize the online reporting portal.
As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site, and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information. These cookie settings can be changed anytime by going to our Cookie Declaration page.
Links to Third Party Websites
Privacy Shield Frameworks
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, NRI is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
NRI’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, NRI remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless NRI proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, NRI commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact NRI at the contact information below.
NRI has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and NRI does not address it satisfactorily, NRI commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel and/or Commissioner, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
We regularly evaluate our information security and privacy policies and procedures, and update them as necessary. However, while we take precautions to protect personal information, we cannot promise or warrant the security of information sent over the Internet. (“Personal information” means any information by which our client’s relocating employee can be identified, including name, mailing address, email address, telephone number, etc.)
We encourage you to periodically review this page for the latest information on our privacy practices.
NRI Relocation, Inc.
1110 W. Lake Cook Road, Suite 301
Buffalo Grove, IL 60089
United States of America