Effective Date: October 3, 2014

Privacy Protection

The RDW Group, Inc. (RDW) an international independent communications and software development agency respects individual privacy and is committed to protecting privacy. Any private information RDW may obtain is handled in a manner consistent with the laws of the states and countries in which we do business. RDW has a tradition of upholding the highest ethical standards in its business practices. This Privacy Policy sets forth the privacy principals RDW follows including our privacy policy with respect to transfers of personal information from the European Union (EU).

Safe Harbor

The United States Department of Commerce and the European Commission have agreed on a set of data protection principals to enable United State (U.S.) companies to satisfy the requirements under EU law that adequate protection be given to personal information transferred from the EU to the U.S. This protocol is referred to as the U.S. /EU Safe Harbor or “Safe Harbor” and has been recognized as providing adequate data protection. RDW is committed to adhering to the principals set forth in the Safe Harbor Framework and remaining Safe Harbor compliant.

Personal Information Obtained and Use

RDW’s websites have functionality that allows interested parties to voluntarily provide certain limited personal information (e.g., name, e-mail address, mailing address, or phone number). RDW collects or records this basic personal information for marketing purposes. RDW does not disclose personal information to non-agent third parties. RDW does not ask for, nor is there any way for us to obtain financial information including, credit card numbers, bank account numbers or any other type of financial information over our websites. RDW does not ask for, nor is there any way for us to obtain social security numbers or benefits, information about race, ethnic origin, religious beliefs, trade union membership, political affiliation, political opinions, or medical information over our websites.

RDW tracks usage on our websites by IP address but this information is not tied to the voluntary personal information a user may provide. RDW tracks usage by IP address simply for internal use to understand usage and improve our web site’s performance and usability.

RDW also builds web sites for clients. In some cases when requested to do so by our clients RDW has access to and does record and track personal information on our client’s websites. This work is generally limited to tracking web site usage to improve web site usability. When working on behalf of our clients RDW operates in accordance with the relevant customer’s privacy policies. In these cases RDW is acting solely as a data processor and our customers remain the data controller. In these cases RDW will use this personal information solely as directed by our clients and in most cases only to improve our client’s web site’s performance and usability.

In regard to RDW’s international clients located in the EU where personal information is transferred from the EU to the US see section “US/EU Safe Harbor” below.

Conditions of Use, Policies, and Revisions

If an individual chooses to visit RDW’s websites, their online visit is subject to this Privacy Policy. This Privacy Policy may be amended from time to time. In particular this Privacy policy will be amended to comply with requirements of the Safe Harbor Framework. The latest version of this Privacy Policy will be posted on our web site. Continued use of the website constitutes acceptance of such changes in the Privacy Policy, except where further steps are required by applicable law.

External Links

The RDW websites may contain links to third party web sites. RDW is not responsible for the privacy practices of these sites and recommends visitors read the privacy statements of each third party website they may visit.

Opt Out, Access, Correction and Choice

Upon request RDW will grant individuals reasonable access to personal information that it holds about them. In addition, RDW will take reasonable steps to permit individuals to correct, amend or delete information that is inaccurate or incomplete. In order to avail oneself of opt out, access or correction an individual must simply contact the RDW Privacy Officer who’s contact information appears below.

RDW does not disclose personal information to non-agent third parties. If this policy were to change RDW would provide individuals with the opportunity to choose (opt out) whether their personal information is to be disclosed to a non-agent third party.

In the event that RDW sends an email communication on our behalf, the email will have clear instructions on how to unsubscribe from future communications. This can be accomplished by either clicking on the unsubscribe link within the email or replying to the email indicating you no longer wish to receive communications from RDW.

Data Integrity

RDW will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. RDW will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.

Security Statement

Along with privacy, security is of utmost importance at RDW. Therefore, substantial investments have been made in RDW’s technology platform. RDW continues to upgrade these capabilities to ensure the security of the data we maintain.

Regular Privacy Compliance Assessment

RDW conducts an annual assessment of its relevant privacy practices to verify adherence to this Privacy Policy. Any employee that RDW determines is in violation of this policy will be subject to disciplinary action up to and including termination.

EU/US Safe Harbor

In regard to our international clients located in the EU where personal information is transferred from the EU to the US our privacy policies are as follows.

RDW is a certified Safe Harbor company, within the meaning of the US Department of Commerce/European Union Safe Harbor privacy framework (the Framework). Among other things, the Framework generally restricts the transfer of EU personal information to RDW operations in the United States, unless there is “adequate protection” for such personal information when it is received in the United States. RDW complies fully with Safe Harbor principles.

In some cases when requested to do so by our clients RDW has access to and does record and track personal information from traffic on our client’s websites. This work is generally limited to tracking web site usage to improve web site usability. When working on behalf of our clients RDW operates in accordance with the relevant client’s privacy policies. In these instances RDW acts solely as a data processor and our clients remain the data controller with respect to such information. RDW therefore acts in accordance with the instructions of such clients regarding the collection, processing and transfer of EU personal information, the provision of access to and rectification of EU personal information, and other matters.

RDW does not disclose any personal information to any non-agent third party. In situations where RDW discloses EU personal information to any third parties formally acting as agents on our behalf RDW will require the recipient to provide at least the same level of protection as is required by the relevant Safe Harbor Principals. If RDW has knowledge that an agent is not handling personal information in a manner consistent with this Privacy Policy RDW will take appropriate action and reasonable steps to prevent or stop the use or disclosure.

RDW also maintains reasonable security measures to safeguard EU personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction, and maintains reasonable procedures to help ensure that such data is reliable for its intended use, accurate, complete, and current.

If any person or party believes that RDW is not in compliance with the Safe Harbor principles, first contact the RDW Privacy Officer listed below. The RDW Privacy Officer’s name, address, e-mail, and telephone number are listed. If an individual does not receive a prompt acknowledgement of an inquiry, or if the inquiry has not been satisfactorily addressed, RDW has agreed to participate in the dispute resolution procedures administered by the European Data Protection Authorities (DPA). RDW pledges to cooperate fully with the DPA in any review or investigation and to resolve complaints brought under Safe Harbor. In the event that the DPA concludes that RDW did not comply with the Safe Harbor Framework, RDW will follow the advice given by the DPA and take appropriate actions and steps to remedy any deficiencies and promote future compliance.

For more information about the Safe Harbor Program, please go to http://export.gov/safeharbor.

Limitation on Applicable Principals

Adherence by RDW to this Privacy Policy and Safe Harbor Framework may be limited (a) to the extent required to respond to a legal or law enforcement obligations; (b) to the extent necessary to meet national security interest; (c) to the extent expressly permitted by an applicable law, rule or regulation.

Questions, Suggestions and Information

If any interested party has questions, suggestions or would like more information regarding our privacy policy, please contact the RDW Privacy Officer:

RDW Privacy Officer
Paul Knaub
RDW Group
125 Holden Street
Providence, RI 02905
401.521.2700
pknaub@rdwgroup.com