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610-834-7600 info@springitl.com

Privacy Policy 

R.J. Berrier (d.b.a. Spring International) is committed to protecting your privacy. This Privacy Policy applies to  any data obtained through the R.J. Berrier (d.b.a. Spring International) corporate website.

TYPES OF INFORMATION WE COLLECT

Website Data
R.J. Berrier (d.b.a. Spring International) will not collect any personal information from you via this website that you do not volunteer. When you use our “Contact Us” form, we ask you to provide your name (first and last), organization, e-mail address, and information relevant to your request. We use this personally identifiable information only to provide you with personalized customer service. If you send email to us, we will use your email address or other contact information in order to respond to your inquiry.

When you visit this website, some non-personally identifiable information may be sent by your browser, including your IP address, browser type and version, [operating system], the pages you visit on the R.J. Berrier (d.b.a. Spring International) website, HTTP header, including referring web site URL, country of origin [and geographic location], and other information. This information may be used to measure and analyze our web traffic, and unless otherwise required by applicable law, such as the GDPR (as defined below), we treat this information as non-personal information.

Third Party Websites
The R.J. Berrier (d.b.a. Spring International) website may contain links to other sites. R.J. Berrier (d.b.a. Spring International) is not responsible for the privacy practices of these other websites. This privacy statement applies solely to the information that we collect by the R.J. Berrier (d.b.a. Spring International) corporate website.

SECURITY AND PRIVACY OF YOUR PERSONAL INFORMATION
R.J. Berrier (d.b.a. Spring International) does not share, sell, or rent any personal information to any third party, ever, for marketing purposes. Your personal information will be securely stored for an indefinite period of time, unless you request otherwise. The information is protected from unauthorized access, use or disclosure.

EUROPEAN UNION RESIDENTS AND EU-US PRIVACY SHIELD
If you reside in a country in the European Economic Area or in Switzerland, then information we collect from you may be subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”)), and the following additional information is provided for your benefit.

The controller of the personal data collected through R.J. Berrier (d.b.a. Spring International) website is:

R.J. Berrier Ltd. (d.b.a. Spring International)

424 E. Elm Street, Suite 200

Conshohocken, PA  19428

If you use the R.J. Berrier (d.b.a. Spring International) website, you acknowledge that your personal data is being processed on the basis of your consent and that information gathered through the R.J. Berrier (d.b.a. Spring International) website may be transferred, used, and stored in the United States.

You hereby consent to the processing of your personal data as described in this Privacy Policy, including the transfer, use, and storage of your personal data in the United States as further described below. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country.  You may withdraw your consent at any time by following the instructions in the Access section below, but this will not affect the lawfulness of processing based on consent before its withdrawal.  However, if you withdraw your consent or decline to provide personal data to us, you may be unable to use the R.J. Berrier (d.b.a. Spring International) website.  You have the right to file a complaint relating to the processing of personal data with a supervisory authority.

For purposes of the GDPR, we use the following companies as subprocessors of personal data:

  • Claire Downes Web Design: Website management
  • 1&1 Internet: Website hosting
  • Google Analytics: Analytics
  • Gravity Forms: Contact Forms
  • WP Mail SMTP: SMTP
  • Dropbox: Document storage
  • Hosting: Data storage
  • Microsoft Office 365: Email correspondence

This Privacy Policy does not apply to information that R.J. Berrier (d.b.a. Spring International) collects from its clients in connection with our employee opinion research studies (“Research Data”).  R.J. Berrier (d.b.a. Spring International) is only a processor with respect to this Research Data, and will only process Research Data in accordance with the instructions we receive from the data controllers (i.e., our clients), as provided in our agreements with the data controllers, or otherwise as required by applicable law.

R.J. Berrier (d.b.a. Spring International) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce, regarding the collection, use, and retention of personal data of natural persons from European Union member countries. R.J. Berrier (d.b.a. Spring International) has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. R.J. Berrier (d.b.a. Spring International) is under the enforcement authority of the Federal Trade Commission. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

R.J. Berrier (d.b.a. Spring International) complies with the following Privacy Shield Principles:

Notice
R.J. Berrier (d.b.a. Spring International) shall inform an individual of the purpose for which it collects and uses the personal information and the types of non-agent third parties to which we disclose or may disclose that information. We shall provide the individual with the choice and means for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to R.J. Berrier (d.b.a. Spring International), or as soon as practicable thereafter, and in any event before we use or disclose the information for a purpose other than that for which it was originally collected.

Choice
R.J. Berrier (d.b.a. Spring International) does not use or disclose personal information to any third party for marketing purposes. For purposes of these standards, opt-out is the default and only choice.

Accountability for Onward Transfer
R.J. Berrier (d.b.a. Spring International) does not typically work with third parties, besides those listed, such as subcontractors in the normal course of business. In the event that disclosure of personal information to a third party becomes necessary, R.J. Berrier (d.b.a. Spring International) shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. We shall ensure that any third party to which personal information may be disclosed subscribes to these principles or is subject to law(s) providing the same level of privacy protection as is required by these principles, and agrees in writing to provide an adequate level of privacy protection. R.J. Berrier (d.b.a. Spring International) recognizes that it may be legally liable for third parties who fail to adhere to these principles. Additionally, R.J. Berrier (d.b.a Spring International) may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Security
R.J. Berrier (d.b.a. Spring International) shall take reasonable steps to protect the information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Likewise, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. R.J. Berrier (d.b.a. Spring International) sends and receives encrypted client-supplied PII via our secure SFTP (Secure File Transfer Protocol) channels. However, R.J. Berrier (d.b.a. Spring International) cannot and does not guarantee the security of information on or transmitted via regular non-secured email via the Internet.

Data Integrity and Purpose Limitation
R.J. Berrier (d.b.a. Spring International) shall only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, we shall take reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.

Access
R.J. Berrier (d.b.a. Spring International) shall allow an individual access to their personal information and allow the individual to correct, amend, or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question, or where the rights of persons other than the individual would be violated.  Additionally, if your personal information is subject to the GDPR, you may have certain additional rights, including the right of restriction of processing of personal data, the right to object to processing of personal data, and the right to data portability.  Individuals may access, amend, or delete their information, and request more information about their rights under the GDPR, by contacting R.J. Berrier (d.b.a. Spring International) at:

R.J. Berrier (d.b.a. Spring International)
424 E. Elm Street, Suite 200

Conshohocken, PA  19428

info@springitl.com

Recourse, Enforcement and Liability
In compliance with the EU-US Privacy Shield Principles, R.J. Berrier (d.b.a. Spring International) commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact R.J. Berrier (d.b.a. Spring International) at:

R.J. Berrier (d.b.a. Spring International)
424 E. Elm Street, Suite 200

Conshohocken, PA  19428

info@springitl.com

R.J. Berrier (d.b.a. Spring International) has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the INSIGHTS ASSOCIATION PRIVACY SHIELD PROGRAM, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visithttp://www.insightsassociation.org/get-support/privacy-shield-program/privacy-shield-eu-swiss-citizens-file-complaint for more information and to file a complaint. These dispute resolution services are provided at no cost to you.

Under certain limited conditions, individuals may invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

Changes to this Policy
R.J. Berrier (d.b.a. Spring International) will occasionally update this Privacy Policy. Please check periodically for changes. If you have any questions or concerns about this Privacy Policy, please email info@springitl.com.