Effective Date: September 1, 2014
Please note, however, that additional or different terms may apply in connection with a particular Service or with respect to other services or relationships. We will inform you of any such additional or different terms either: (i) before we collect Personal Information that will be subject to those terms; or (ii) before we use or disclose previously collected Personal Information in accordance with those terms. We also separately may solicit your consent to particular uses and/or Disclosures of your Personal Information. To the extent that there is any conflict between this Policy and any such separate consent or such other terms, your consent and/or the other terms (as applicable) will apply.
We may collect more or different Personal Information about you in connection with some Services than others. We also may provide your Personal Information to third parties in order to provide the Services that you request, to carry out the purposes for which you provide your Personal Information to us, or otherwise in accordance with this Policy and/or your express consent.
WE. 3 Centerpointe Drive, Suite 500, Lake Oswego, OR 97035 is the responsible body for the purposes of data protection legislation.
By providing us with your Personal Information (including by providing any consent for us to obtain your Personal Information from a third party) and/or by using this Site or our Services, you agree that we may use and disclose your Personal Information in accordance with this Policy. If you do not consent to these terms, you should not use this Site or our Services or otherwise provide us with any Personal Information.
See below for information about other consents.
In addition to the other terms that are defined in this Policy, the following terms have these meanings:
“Disclosing” (and variations such as “Disclosure” or “Disclose”) means any and all of the following: collecting, receiving, accessing (or barring access), verifying or investigating, storing, processing, combining, fulfilling, revealing, displaying, sharing, making available, transferring, destroying, enforcing, selling or leasing or licensing, and otherwise voluntarily or involuntarily using or dealing with Personal Information.
“Personal Information” means information that we are required by law to protect and that: (a) personally identifies you; or (b) may not personally identify you, but reasonably might be used to identify you or your computing device (provided that applicable law requires us to consider such information to be personally identifiable). Personal Information does not include information that does not identify you and cannot reasonably be used to identify you or your computing device on an individual basis, such as “de-identified,” anonymized, or aggregated data.
“Sensitive Personal Information” means Personal Information that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life, or trade-union memberships.
We will process personal data that is transferred to us from the European Economic Area (EEA) in accordance with the safe harbor principles agreed between the United States Department of Commerce and the European Commission (Safe Harbor Principles). These principles enable US companies to satisfy the EU requirement set out in the EU Data Protection Directive that personal data transferred from the EEA to the United States be adequately protected.
WE has taken measures to comply with the US-EU Safe Harbor Framework and US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland (collectively, the “Safe Harbors”). WE adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.
Among other things, this means that if your Personal Information is subject to the Safe Harbors, we will give you the opportunity to opt-out of any use of your Personal Information or any Disclosure of your Personal Information to a third party for a purpose that is incompatible with the purpose(s) for which it was originally collected or which you subsequently have authorized. To the extent that we provide your Personal Information to a third party that is acting as our agent, we will require the third party to subscribe to the Safe Harbor Privacy Principles or verify that it is subject to legal or contractual requirements to provide at least an equivalent level of privacy protection. We also will take commercially reasonable steps to ensure that your Personal Information is reliable for its intended use, accurate, complete, and current.
To learn more about the Safe Harbors, and to view our certification page, please visithttp://www.export.gov/safeharbor/.
Personal Information We May Collect
Below are examples of the types of Personal Information that we may collect or receive from you or others in order to provide our Services or otherwise in connection with your use of our Site. We make commercially reasonable efforts only to collect such Personal Information as is relevant to its intended purpose(s). Please refrain from providing us with more or different Personal Information than we request (for example, do not include Sensitive Personal Information or other private information like a government identification number in a resume – wait until we ask for such information).
Cookies and Other Technologies
If you use the Site, it may collect certain Personal Information about you and/or your computer or other access device through the use of “cookies” and other tracking software or tracking mechanisms (collectively, “Technologies”). In general, a cookie is a small text file that is saved to the hard drive of your access device (such as a computer, phone, tablet etc.) in order for us and/or our service providers or business partners to collect data about your use of the Site and/or other webpages that you have visited. To the extent required by law, we may separately solicit your affirmative consent to the placement of cookies or other Technologies on your computer or other access device and/or for the collection of Personal Information through such Technologies.
This section describes the Technologies that we use on the Site. For information about cookies and other Technologies that may be used by third parties, see “Third Party Services” below.
The Technologies that we may use include:
The Technologies that we may use may differ depending upon the device that you use to access the Site and may change as Technologies and access channels develop or change.
The types of Personal Information that we and/or third parties may automatically collect through cookies or other Technologies may include, but are not limited to, your IP address and information about your browser, including whether you are accessing the site through a mobile device. We generally may use or otherwise Disclose this information in order to enable Third Party Services, to provide Services to you, and for purposes of Site functionality (e.g. to remember your login information), but we generally reserve the right to use and Disclose Personal Information obtained through Technologies for any lawful purpose.
For example, we may collect certain kinds of information about your computer to facilitate, evaluate and verify your use of the Site or our Services, including the frequency with which you visit the Site, the times and dates of your visits, the pages you reviewed, types of Services used, and how many users we receive daily. This information is generally collected in aggregate form (or anonymized, de-identified or pseudonymized), without identifying any user individually, although IP addresses and session IDs may be tracked in relation to your purchase activity as part of WE’s customer order review and fraud prevention efforts. We also use the IP Address of your computer addresses to identify server problems, administer the Site, and compile aggregated statistics for marketing and research purposes. We use navigational data, including log files and click-stream data, to identify information about your web browser and operating system, and the time period in which you visit the Site or a portion of the Site. This information is used to administer the Site, improve Site content, and compile aggregated statistics for research purposes.
California Disclosure. CA Bus. & Prof. Code § 22575 requires us to disclose our how Site responds to Web browser “do not track” signals and/or other mechanisms that seek to provide consumers with the ability to control the collection of their Personal Information through online tracking Technologies for certain purposes, such as targeted or behavioral advertising.
Uses and Disclosures of Personal Information
We may use and Disclose Personal Information to provide Services to you, to administer the Site, and otherwise to perform obligations, exercise rights, and further the activities for which the Personal Information was provided to us.
Subject to applicable law, other reasons that we may use or Disclose your Personal Information include, but are not limited to:
It is not possible for us to list every lawful use that we might make of Personal Information, so the Disclosures described above are general, non-exclusive, illustrations. We reserve the right to engage in any lawful use or Disclosure of Personal Information that is consistent with this Policy. Note, however, that we will not engage in any of the uses described above to the extent that they are prohibited by applicable law.
We may obtain separate consents from you (or provide separate disclosures to you) regarding particular uses or Disclosures of Personal Information, to the extent that we are required to do so.
Please note that the Third Party Services that we may use may change from time to time and we may update this Policy to provide additional or updated information accordingly.
We use what we believe to be commercially reasonable measures to protect your Personal Information from loss, misuse, or unauthorized access, disclosure, alteration or destruction.
Nevertheless, please be advised that no security measure, system, or control is infallible. We accordingly do not guarantee the security or confidentiality of Personal Information and disclaim any express or implied warranties, duties or conditions in that regard. If any applicable law imposes on us a duty with respect to these matters that cannot be disclaimed, you acknowledge and agree that our commercially reasonable precautions shall be considered to be satisfy that duty unless (and only unless) we have engaged in willful misconduct.
Please also note that you also have a role in the security of your Personal Information. For example, you should not provide us with Personal Information that we do not request, you are responsible for controlling access to any personal computing device through which your Personal Information may be stored or accessed, and you are responsible for safeguarding any passwords or other log-in credentials to may be used to access to your Personal Information.
Data Integrity, Access, and our Legal Notices Address
We also maintain what we believe to be commercially reasonable measure to ensure that Personal Information is reliable for its intended use and is accurate, complete, and current. If you want to access, change, or delete Personal Information that we may maintain about you, you may submit a request to us through our Site, or by writing to us at WE, Attn: Privacy, 3 Centerpointe Drive, Suite 500, Lake Oswego, OR 97035 (our “Legal Notices” address). We will honor requests submitted through other means if required by law or if we determine in our sole discretion to do so. In connection with certain Services and Personal Information, you also can do so by logging into your account and updating your Personal Information directly.
We reserve the right to deny any request to access, change, or delete Personal Information, subject to applicable law. For example, we may deny a request to access Personal Information where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where such access would compromise the rights of other persons.
We may respond to a request to access Personal Information by supplying a copy of or access to the relevant Personal Information within a reasonable time. As a general matter, this means that we will respond in no less time than is needed by us or our service providers to retrieve that information from our systems or records in the ordinary course of business.
We also may keep a record of changes or deletions and use or Disclose that record for lawful purposes. If you ask us to delete Personal Information, the information may be immediately deleted. However, if technical constraints prevent us from easily doing so, we instead may take reasonable measures to prevent internal or external access to such information until it is deleted from our systems or records (such as by being overwritten).
Subject to any legal right that you may have to require us to delete your Personal Information (e.g., if you terminate your account), we may keep Personal Information for as long as necessary for our business and legal needs and we reserve the right to retain it to the fullest extent required or permitted by law. Note, however, that you should retain your own record, because we also may delete Personal Information in our discretion at any time, unless the deletion would be detrimental to your legitimate interests or it would violate retention periods set by law, statute or contract.
We do not charge for responding to requests to access, change, or delete Personal Information. If we have a duty to require third parties to delete or cease using Personal Information, we may satisfy that duty by sending them notice to do so without further action on our part (except as expressly required by law).
By providing us with your Personal Information and/or by using this Site or our Services, you also consent to the following:
To the extent required by applicable law, we also may separately solicit your consent to these and/or other matters.
You may withdraw or restrict any or all of the consents above by doing all of the following: (a) writing us at our “Legal Notices” address or sending us an email at Privacy@waggeneredstrom.com and telling us which consents you withdraw and the date you plan to do so; (b) deleting all Site or other WE accounts that you have created or use and that are relevant to the consent that will be withdrawn; and (c) ceasing all use of the Site or our Services which are so relevant. If you withdraw your consent(s) in this manner, we will use commercially reasonable efforts to cease further uses and Disclosures of Personal Information covered by the withdrawal, except to the extent that applicable law permits us to continue to use or Disclose your Personal Information in that manner without your consent. We will make those efforts within a time reasonably allowing us to process your request. We do not charge for responding to such requests.
Any such withdrawal will not apply to any use or Disclosure of Personal Information that may have occurred before the withdrawal or to uses or Disclosures with respect to which withdrawal is not allowed or permitted by applicable law, this Policy, or any other consent, contract, or agreement that we might have from or with you. If you withdraw and subsequently renew your consent (e.g., by again using the Site or submitting a new resume to us), we may rely on such renewed consent.
Our Site, our Products, and our Services are not intended to be used by children under the age of 13 (or minors generally) and we do not want to collect information from minors. If a child’s parent or a guardian believes their child may have provided Personal Information to us, write us at our “Legal Notices” address and we will use commercially reasonable efforts to delete that Personal Information, subject to applicable law and this Policy.
When required by applicable law, however, we may provide you with advance notice of any changes to this Policy and with an opportunity to object to such changes. If you exercise your right to object, the changes will not become effective with respect to your information, but your ability to use our Products or Services may be terminated or impaired. We will explicitly notify you of the consequences of objection or non-objection to the extent and in the manner required by law.
At least once a year we will investigate our compliance with this Policy through a re-assessment. We have procedures for taking appropriate action against those who violate this Policy when they are required to follow it. For example, we might discipline an employee who willfully violates this Policy (subject to applicable law).
Complaints and Dispute Resolution
3 Centerpointe Drive, Suite 500
Lake Oswego, OR 97035
Please include your name, address, and/or e-mail address when you contact us. In your correspondence, please indicate with as much detail as possible the location on this Site or otherwise where you provided your Personal Information.