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Dwellworks Direct User Privacy Policy

Dwellworks Privacy Policy

Purpose and Scope

This Privacy Policy (the "Policy") for Privacy Shield applies to:

(together referred to as "Dwellworks").

 

For all other purposes, this Policy applies to all affiliated entities of Dwellworks including Irish Relocation Services Limited; Dwellworks GmbH; County Homesearch International Limited; Dwellworks Hong Kong Limited; Dwellworks Canada, Inc.; Dwellworks Costa Rica Ltda.; Dwellworks Mexico S. de R.L. de C.V.; Dwellworks Australia Pty. Ltd.; and Dwellworks Netherlands B.V.

 

Dwellworks, LLC is a limited liability company incorporated in Ohio, USA with its headquarters at 1317 Euclid Avenue, Cleveland, Ohio 44115. The other Dwellworks companies are wholly-owned subsidiaries of Dwellworks, LLC.

 

Due to the global nature of the mobility industry and Dwellworks’ business operations, the transfer of personal data across national borders may occur.  Dwellworks respects and strives to protect the privacy of its customers.  Personally identifiable information and sensitive personal data that identifies or describes a living person (hereinafter “Personal Data”) which is collected, used, or disclosed by or on behalf of Dwellworks is protected in accordance with the laws of the countries in which Dwellworks operates. 

 

This Policy governs the way Dwellworks manages and processes Personal Data collected in the process of delivering relocation services in the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) or Switzerland that is subsequently transferred to the United States as well as Personal Data that is collected in the process of delivering relocation services elsewhere in the world including within the United States.

 

This Policy applies to Personal Data of direct customers and to Personal Data of any other individuals (such as business contacts and supply chain partners) other than employees (including applicants for employment and former employees) of Dwellworks (“you”).

 

This Policy applies to Personal Data received by Dwellworks in any format, including electronic, paper, or verbal. 

 

For the purposes of the General Data Protection Regulation (EU 2016/679) (GDPR) in the European Union, Dwellworks will be a data controller of Personal Data relating to its direct customers which is obtained and processed in the course of providing relocation services and relating to its supply chain partners.

 

This Policy lays out the general data protection principles utilized by Dwellworks and general rights granted to you under GDPR. For more specific information regarding your data and rights, please see our Privacy Notice. If you are a California resident, you may have additional rights under the California Consumer Privacy Act. For more specific information regarding your data and rights, please see our California Privacy Notice for direct customers.

 

 

Principles

Types of Data Collected

Personal Data collected by Dwellworks is limited to information necessary to conduct business.  Personal Data collected includes but is not limited to: name, address, government identification number (i.e., social security number, national identification number, tax payer identification number, passport information, driver's license), date of birth, phone number, email address, Office of Foreign Assets Control (OFAC) information, financial information, bank account information, and any other information provided by you to Dwellworks.

 

Notice

Dwellworks will inform you about the purposes for which it collects and uses Personal Data, the types of third parties or agencies to which it discloses such information, and the choices which Dwellworks offers to limit the use and disclosure of Personal Data.

 

The sharing of Personal Data by Dwellworks with its network of third-party suppliers of relocation-related services is necessary for the purpose of providing relocation services to you. Notice will be provided in clear and conspicuous language when you are first asked to provide Personal Data or as soon as practical thereafter. 

 

If Dwellworks receives Personal Data from its subsidiaries, affiliates, or other entities in the EEA or Switzerland, it will use and disclose such Personal Data in accordance with the notices provided by such entities.

 

 

Choice

Dwellworks offers you the opportunity to opt out of disclosing your Personal Data to a third party or to consent to the use of the information by Dwellworks for a purpose other than which it was originally collected or subsequently authorized.  For sensitive data (which includes health data and other types of data classified as "special categories of personal data" under the GDPR), Dwellworks offers you the opportunity to affirmatively and explicitly consent to the disclosure of the information to a third party or to the use of the information by Dwellworks for a purpose other than which it was originally collected or subsequently authorized.

 

Onward Transfer

Dwellworks will only transfer Personal Data to a service provider, vendor, or other third party acting as a processor of Personal Data for Dwellworks where that party has provided assurances that it provides at least the same level of privacy protection as is required by this Policy.  Where Dwellworks becomes aware that a party is using or disclosing Personal Data in a manner contrary to this Policy, Dwellworks will take reasonable and appropriate steps to prevent or stop the use or disclosure of that Personal Data.

 

On occasion, Dwellworks may be required to share personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

Security

Dwellworks takes reasonable steps to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction.  These precautions include but are not limited to password protections for online systems and restricting access to Personal Data to the legal department or to your relocation consultant.  Individuals who have access to Personal Data are aware of their responsibilities to protect the security, confidentiality, and integrity of the information.

 

Data Subject Rights

Under the GDPR (and elsewhere as applicable), Personal Data is protected by legal rights, which include your rights to request access to or amendment of your Personal Data, to request erasure of your Personal Data, to object to processing of your Personal Data, to require restriction of processing of your Personal Data, to request the transfer of your Personal Data to another party or to withdraw consent at any time where Dwellworks is relying on consent to process such Personal Data. Where Dwellworks is a data controller, Dwellworks will respond to any request from you to exercise any such right within one month. Where Dwellworks is a data processor, Dwellworks will forward any request from you to exercise any such right to the relevant data controller.

 

Under the GDPR (and elsewhere as applicable), you have the right to make a complaint about Dwellworks' use of your Personal Data to a relevant supervisory authority for data protection matters. If you would like to exercise your rights under GDPR or CCPA, please complete this form.

 

You can access your Personal Data and can correct or amend it if it is inaccurate or incomplete.  Subject to applicable data protection laws, Dwellworks reserves the right to deny or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to your privacy. 

 

You can review or update your Personal Data by contacting the Compliance Department at compliance@dwellworks.com.

 

Data Integrity

Dwellworks will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you.  Dwellworks will take reasonable steps to ensure that Personal Data is reliable, complete, accurate, and current.  You are asked to inform Dwellworks at compliance@dwellworks.com or your relocation consultant immediately in the event of changes in Personal Data.

 

Enforcement, Verification, and Dispute Resolution

Associates and supply chain partners who violate data privacy rules may be subject to potential civil and/or criminal liability.  Dwellworks conducts periodic reviews of its privacy practices to verify adherence to this Policy and the Privacy Shield principles.  This Policy may be updated occasionally to reflect changes to Dwellworks’ privacy practices.

You should contact Dwellworks if there is reason to believe that the security of your Personal Data has been compromised.  Dwellworks will investigate and attempt to resolve complaints regarding use and disclosure of Personal Data.  Where necessary under applicable data protection laws, Dwellworks will report any misuse or other personal data breach to the relevant regulatory authorities.

For any complaints that cannot be resolved with Dwellworks directly, Dwellworks has selected the ICDR/AAA as its Independent Recourse Mechanism in relation to such unresolved complaints (as further described in the Privacy Shield Principles). The link to the ICDR/AAA for making complaints is as follows: http://go.adr.org/privacyshield.html.

Dwellworks will provide, at no cost to you, the services of the ICDR/AAA by which your complaint or dispute will be investigated and expeditiously resolved.

A binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.

Dwellworks is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

 

Contact Us

Contact information: Hank Roth, Dwellworks’ Chief Privacy Officer or Michael Wallace, Dwellworks’ Data Protection Officer can be reached for complaints, questions, or information regarding Dwellworks' Policy and Privacy Shield participation.

Dwellworks will respond to complaints or inquiries within a reasonable time but in no event later than one month after such complaint or inquiry.

 

Declarations Regarding the Privacy Shield

For the purposes of this Policy, references to "Privacy Shield" shall be references to the EU-US Privacy Shield Framework and to the Swiss-US Privacy Shield Framework, as applicable, and references to "Privacy Shield Principles" shall be references to the applicable privacy principles contained within the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework respectively.

Before sharing Personal Data concerning a resident of the EU (or EEA) or a resident of Switzerland with a third party, Dwellworks will verify that the third party holds Personal Data in a manner consistent with this Policy, and certifies compliance with the European Union’s and Switzerland's data protection laws and with the Privacy Shield requirements. In particular, Dwellworks will ensure that Dwellworks will only transfer such Personal Data to third parties in countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, or to third parties who have signed specific contracts approved by the European Commission which give personal data the same protection it has in the EU or to third parties based in the USA if they are also part of the Privacy Shield.

Dwellworks complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (or EEA) and Switzerland to the United States. Dwellworks has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Dwellworks' participation in the Privacy Shield applies to all Personal Data that is received from the European Union, European Economic Area or Switzerland. Dwellworks will comply with the Privacy Shield Principles in respect of such personal data.

Dwellworks’ accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Dwellworks 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 Privacy Shield Principles, unless Dwellworks proves that it is not responsible for the event giving rise to the damage.