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Privacy Policy

PRIVACY POLICY
PRIVACY POLICY

This Privacy Policy defines Company objectives for securing and protecting personally identifiable information and other information.

The types of personal data includes names, addresses, phone numbers, birthdates, Social Security numbers, tax identification numbers, national insurance numbers and financial account numbers.

Please click here for our Privacy Shield Policy

POLICY/PROCEDURE

I. OBJECTIVES

  1.  The Company adheres to federal, state, and local regulatory and customer privacy requirements.
  2.  The Company collects personally identifiable information when voluntarily submitted by our online and onsite visitors. The information provided is used to fulfill specific requests, unless given permission to use it in another manner.
  3.   In connection with services we provide, the Company may collect the following types of information:
    • Personally Identifiable Information. Names, addresses, email addresses, phone numbers, Birth dates, social security, tax identification, financial account and national insurance numbers company information,
    • Cookies. When a visitor views Company websites, a cookie is sent out to the viewer's Computer that will identify the visitor's browser. These cookies enable the website to recognize the visitor's computer the next time the visitor views the Company website. These cookies will be used exclusively to collect information concerning the use of the website. Cookies contain no personally identifiable data, so the visitor personally identifiable information is not collected or retained.
    • User Communications. When a visitor sends an email or other communication to the Company, these communications may be retained in order to process inquiries, respond to requests, and improve overall services.
    • Affiliated Websites. Personal information that a visitor may provide to websites affiliated with the Company may be sent to the Company in order to deliver a services the Company or other entities affiliated with the Company provides. The Company processes such information in accordance with this Policy.
  4.  The Company reserves the right to collect and process personal information in the course of providing services to our clients without the knowledge of individuals involved. Where the Company collects personal information from individuals within the European Union, upon request, the Company will inform them about the types of personal information collected from them, the purposes for which it was collected, and uses of the information, and the types of non-agent third parties to which the Company discloses that information.
  5.   As a general rule, the Company will not disclose personally identifiable information except when the Company is required or permitted per customer agreement, law (including pursuant to national security or law enforcement requirements) or otherwise, such as when the Company believes in good faith that the law requires disclosure or other circumstances outlined in this Privacy Policy require or permit disclosure. Examples of when the Company may share information are as follows:
    • The Company may share information with governmental agencies or other companies assisting in fraud prevention or investigation. The Company may do so when: (1) permitted or required by law; (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions, or, (3) investigating fraud which has already taken place. This information however, is not provided to these companies for marketing purposes.
    • Permitted transfers of information, either to third parties or within the Company, include the transfer of information from one jurisdiction to another, including transfers to the United States from other countries, including the European Union and Switzerland, and from the United States to other countries, including the European Union and Switzerland. Subject to applicable legal requirements, including in the European Union and Switzerland, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the personal information is collected or accessed.
  6.  The Company takes reasonable steps to protect personally identifiable information. To prevent unauthorized access or disclosure of personally identifiable information, maintain data accuracy, and support the appropriate use and confidentiality of personally identifiable information, either for its own purposes or on behalf of our clients, the Company has put in place appropriate physical, technical, and managerial procedures to safeguard and secure the personally identifiable information and data the Company possesses.
  7.  The Company collects and maintains personally identifiable information in a manner that is compatible with the purpose for which it was collected and maintained, or as subsequently authorized by an individual or client. To the extent necessary for such purposes, the Company takes reasonable steps to confirm that personal information is accurate and complete with regard to its intended use.
  8.  The Company complies with the EU-U.S. Privacy Shield Framework and the 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 and Switzerland to the United States, respectively. The Company 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/.
  9.  Rust Consulting receives EU and Switzerland personal data from its customers which is transferred to the U.S. for processing and handling, as applicable, and transfers back to the EU and Switzerland fully composed data (including such personal data) for print, notification, and distribution services within the EU and Switzerland. In certain cases, such personal data is received or processed by third parties in the U.S. for storage and other services.
  10.   The Company utilizes a self-assessment approach support compliance with this Privacy Policy.
    • The Company periodically verifies that related policies are accurate, comprehensive for the information intended to be covered, prominently displayed, implemented, and are in conformity with the principles of this Privacy Policy.
    • The Company encourages interested persons to raise any concerns with the Company. The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Policy.
    • With respect to any complaints relating to this Privacy Policy that cannot be resolved through our internal processes, the Company has agreed to participate in the dispute resolution procedures of the panel established by the European Union Data Protection Authorities to resolve disputes pursuant to the Privacy Shield Principles.
    • If the Company, the European Data Protection Authorities, or other qualified government agencies determines that the Company has not complied with this Privacy Policy, the Company shall take appropriate steps to address any adverse effects related to non-compliance and to promote future compliance.
    • If the Company determines an employee is in violation of this Privacy Policy, that employee will be subject to the Company's disciplinary process.
  11.  In the event that the Company merges, is acquired by or sells it assets to a third party, the Company may disclose personally identifiable information as is reasonably necessary in connection with any such merger, acquisition or sale. Any such party with whom the Company merges or whom acquires some or all of the assets of the Company may not have the same or similar privacy guidelines as set forth in this Privacy Policy and may use personally identifiable information in a manner other than as set forth herein.
  12.  This Privacy Policy shall be reviewed annually and updated as necessary to comply with applicable regulations.
  13.  The Company will post any revised Privacy Policy on its website, or a similar website that replaces that website.
  14.  Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice provided to the client, any contract or other agreement with the client, and application enforcement laws.
  15.  The Company will cooperate with the appropriate regulatory authorities, including local data protection regulatory authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between the Company and an individual.
PRIVACY SHIELD POLICY

Please click here for the Rust Consulting, Inc's Privacy Policy

Rust Consulting, Inc. ("Rust") has certified to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, the "Privacy Shield Frameworks") with the U.S. Department of Commerce regarding the collection, use, retention and transfer of Personal Data (as defined below) from European Union ("EU") member countries and Switzerland. (Rust's parent company, Exela Technologies, also maintains certification to the EU-U.S. Privacy Shield Framework.) Rust commits to adhering to the Privacy Shields' Principles (as set out in each of the Privacy Shield Framework) for all Personal Data received by Rust from EU member countries and Switzerland in reliance on the respective Privacy Shield Framework. If there is any conflict between the policies in this Rust https://www.privacyshield.gov/list Shield Policy ("Privacy Shield Policy") and the Privacy Shield Frameworks, the Privacy Shield Frameworks shall govern. To view a list of organizations that participate in the Privacy Shield including Rust, please visit https://www.privacyshield.gov/.

A. Definitions

"Individual" means an individual with respect to whom any given Personal Data covered by this Privacy Shield Policy refers.

"Personal Data" means information relating to an individual residing in the EU or Switzerland that can be used to identify that individual either on its own or in combination with other readily available information. Such information includes names, addresses, email addresses, phone numbers, birthdates, social security numbers, tax identification numbers, national insurance numbers and financial account numbers.

"Sensitive Personal Data" means Personal Data regarding an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.

B. Scope and Responsibility

This Privacy Shield Policy applies to Personal Data transferred from EU member countries and Switzerland to Rust's operations in the U.S. in reliance on the respective Privacy Shield Framework.

C. Privacy Shield Principles

1. Notice

Through its Privacy Policy, Rust notifies Individuals covered by this Privacy Shield Policy about its practices regarding its collection and use of Personal Data received by Rust from EU member countries and Switzerland in reliance on the respective Privacy Shield Framework, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, the rights of Individuals to access their Personal Data. To the extent permitted by each Privacy Shield Framework, Rust reserves the right to use, process, and transfer Personal Data in the course of providing services without the knowledge of applicable Individuals.

2. Choice

Except to the extent permitted by each Privacy Shield Framework, if Personal Data covered by this Privacy Shield Policy is to be used or disclosed for a purpose that is materially different from the purpose for which the Personal Data was originally authorized to be used or disclosed, or will be disclosed to a non-agent third party of Rust, Rust will provide Individuals with an opportunity to opt out of such uses or disclosures. Individuals may request to opt out of such uses or disclosures of their Personal Data by sending a request to: privacyshield@rustconsulting.com.

If Sensitive Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, Rust will obtain the Individual's explicit consent prior to such use or disclosure.

3. Accountability for Onward Transfer

In the event we transfer Personal Data covered by this Privacy Shield Policy to a third party acting as a controller, we will do so consistent with any notice provided to Individuals and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Individuals, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If Rust has knowledge that a third party acting as a controller is processing Personal Data covered by this Privacy Shield Policy in a way that is contrary to the Privacy Shield Principles, Rust will take reasonable steps to prevent or stop such processing.

With respect to our agents, we will transfer only the Personal Data covered by this Privacy Shield Policy needed for an agent to deliver to Rust the requested product or service. Furthermore, we will (i) permit the agent to process such Personal Data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with Rust's obligations under the Privacy Shield Principles; and (iv) require the agent to notify Rust if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

4. Security

Rust takes reasonable and appropriate measures to protect Personal Data covered by this Privacy Shield Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks applicable to the processing of such Personal Data and the nature of the Personal Data.

5. Data Integrity and Purpose Limitation

Rust limits the collection and use of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes for which it is collected and used, including the performance of services for its customers. Rust does not use such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the applicable Individual.

Rust takes reasonable steps to confirm that Personal Data is accurate, complete, and current and reliable for its intended purposes. Rust also takes reasonable and appropriate measures to comply with the requirements under the Privacy Shield Principles to limit retention of Personal Data in identifiable form to as long as it is needed for the purpose for which it is collected or used. To the extent the Privacy Principles are applicable to Personal Data it retains, Rust adheres to the Privacy Shield Principles for as long as it retains such Personal Data.

6. Access

Rust will take reasonable steps to enable Individuals to correct, amend, or delete Personal Data that is demonstrated to be inaccurate or has been processed in violation of the Privacy Shield Principles. Requests for access, correction, amendment, or deletion should be sent to: privacyshield@rustconsulting.com.

7. Recourse, Enforcement, and Liability

Rust's compliance with the Privacy Shield Principles is subject to the investigation and enforcement powers of the Federal Trade Commission.

Rust commits to resolve complaints about our collection and use of your Personal Data. If you have any questions or complaints regarding this Privacy Shield Policy our use and collection of your Personal Data, please contact Rust at: privacyshield@rustconsulting.com.

Rust has further committed to refer unresolved complaints under the Privacy Shield Principles to the EU Data Protection Authorities (DPA). If you submit a complaint but do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.privacyshield.gov/Data-Protection-Authorities for more information and instructions on how to file a complaint with the DPA.

In certain circumstances, the Privacy Shield Frameworks provide the right to elect binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles in each of the Privacy Shield Frameworks.

Disclaimer

This notice only summarizes the proposed settlement. If you have additional questions, you should contact the Settlement Administrator at 1-800-711-7362.

PLEASE DO NOT CALL USAA LIFE, THE COURT OR THE COURT’S CLERK’S OFFICE TO INQUIRE ABOUT THIS SETTLEMENT OR THE CLAIM PROCESS.

View the Privacy Policy