Consistent with its commitment to protect personal privacy, Everett complies with the principles set forth in the EU-US Privacy Shield Framework (the “Privacy Shield Privacy Principles”) as adopted by the U.S. Department of Commerce regarding the collection, use and retention of personal information from the European Economic Area (“EEA”) (which includes the 28 member states of the European Union (“EU”), plus Iceland, Liechtenstein and Norway) to the United States.
Collection and Use of Visitor Information
Everett also collects information you provide to us. As a visitor to the Everett website, or as one who has otherwise requested information about Everett, you may choose to provide us with your name, email address, and other contact information, such as your mailing address and telephone number. We will use the information you provide us for the purpose of responding to your request and to provide you with services.
Third Party Applications
When you visit our Website, we collect and temporarily store information about the Internet connection and the date and time of the visit through the use of tracking technologies. We use technologies such as cookies, beacons, tags and scripts, which are used by Everett and Google Analytics.
Disclosure of Information
Everett will not sell your personal information to third parties. If you have voluntarily submitted information to us through an email, by telephone, or otherwise, Everett maintains your privacy by ensuring that the information is distributed only within Everett or to third party agents who help us provide services to you. This enables us to respond to your requests about our services and our company.
We may also disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, 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 Everett is involved in a merger, acquisition, or sale of all or a significant portion of its assets, you will be notified via a prominent notice on our Website of any material change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
User Access and Choice
We will retain your information for as long as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our Website includes links to our newsletters and other marketing materials. 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 or by contacting us at firstname.lastname@example.org.
The security of your personal information is important to us. We follow generally accepted standards, such as secure socket layer (SSL) to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
Links to 3rd Party Sites
Social Media Widgets
Notifications of Changes
This document was last updated on November 23, 2016.
Everett has no direct relationship with the individuals whose Personal Information it processes under the direction of its Clients in the role of a data processor; however, Everett’s contracts with such Clients require that such Clients comply with data protection laws, which includes providing appropriate notice to data subjects regarding the purposes for which their Personal Information is being collected.
Purpose Limitation and Use
Everett will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Everett will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.
To the extent permitted by the Privacy Shield Privacy Principles and Safe Harbor Principles, Everett reserves the right to process Personal Information provided by a Client in the course of providing professional services to such Client without the knowledge of individuals involved, including any supplementation of the information through publicly available sources as Everett may deem necessary to fulfill its obligations to its Client.
Everett will retain Personal Information we process on behalf of our Clients for as long as needed to provide services to our Client. As for Personal Information collected on our Website, we will retain the information for as long as needed to provide the services to the Client. Everett will also retain and use any such Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Transfers and Disclosures to Third Parties
Everett will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
Access and Correction
Recourse, Enforcement and Liability
Any questions or concerns regarding the use or disclosure of Personal Information subject to this Policy should be directed to the Everett as set forth below. Everett 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. Everett will respond to any such questions or concerns within 30 days or receipt. Individuals who submit a question or concern to Everett and who do not receive acknowledgment from Everett of the inquiry or who think their question or concern has not been satisfactorily addressed may then contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Limitation On Application Of Principles
Adherence by Everett to these Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations and (c) to the extent expressly permitted by an applicable law, rule or regulation.
EFFECTIVE DATE: November 23, 2016