GRM Website Privacy InformationGRM Information Management Systems, Inc. and its affiliates (“GRM”) are committed to protecting the privacy of its customers. We have adopted this online privacy statement to ensure that your personal information is secure and your privacy respected, and to provide you with information about what type of information is gathered and tracked on our web site, how the information is used, and with whom the information is shared. Please review the policy terms carefully before using this web site. By using this site, you are agreeing to the terms set forth below.
COLLECTION OF PERSONAL INFORMATIONIn order to offer you a more consistent and personalized experience in your web site interactions with GRM, we ask you to provide personal information, such as your e-mail address, name, home or work address or telephone number. We may also collect information about your visit, including the pages you view, the links you click and other actions taken in connection with the GRM site and services. This information is collected to better enable GRM to assess your specific needs, whether answering specific questions you may have relating to GRM and the services it offers, or providing you with various materials creat ded by GRM in response to such questions. Your use of the GRM website constitutes your consent to collect the personal information you provide.ˆ back to the top
DEFINITIONSFor purposes of this Policy, the following definitions shall apply: “GRM” means GRM, 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 GRM 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, ethnic origin, political opinions, 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, GRM will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
Privacy PrinciplesThe privacy principles in this Policy have been developed based on the Safe Harbor Principles.Where GRM receives personal information from its subsidiaries, customers, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.Data Integrity: GRM will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. GRM will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.Access and Correction: Upon request, GRM will grant individuals reasonable access to personal information that it holds about them. In addition, GRM will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.Security: GRM will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.ENFORCEMENT: GRM will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that GRM 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 GRM Privacy Officer at the address given below. GRM 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. For complaints that cannot be resolved between GRM and the complainant, GRM has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:
- for disputes involving all personal information received by GRM from Switzerland, GRM agrees to cooperate with the Swiss FDPIC;
- for disputes involving employment-related personal information received by GRM from the EEA, GRM agrees to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
- For disputes involving all other personal information received by GRM from the EEA, GRM has agreed to JAMS dispute resolution services. Individuals who submit a question or concern to GRM and who do not receive acknowledgment from GRM of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the JAMS Safe Harbor Dispute Resolution Program by email. Inquiries should identify GRM as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether JAMS may share the details of the inquiry with GRM. JAMS will act as a liaison to GRM to resolve these disputes.