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Walton
Construction, respects individual privacy and values the
confidence of its customers, employees, vendors, consumers,
business partners and others. Walton Construction strives to
collect, use and disclose Personal information in a manner
consistent with the laws of the countries in which it does
business, and has a tradition of upholding the highest
ethical standards in its business practices. Walton
Construction abides by the Safe Harbor Principles developed
by the U.S. Department of Commerce and the European
Commission and the Frequently Asked Questions (FAQs) issued
by the Department of Commerce on July 21, 2000. This Safe
Harbor Privacy Policy (the "Policy") sets forth the privacy
principles that Walton Construction follows with respect to
transfers of Personal information anywhere in the world,
including transfers from the European Economic Area (EEA)
(which includes the twenty-five member states of the
European Union (EU) plus Iceland, Liechtenstein and Norway)
to the United States.
The United
States Department of Commerce and the European Commission
have agreed on a set of data protection principles and
frequently asked questions (the "Safe Harbor Principles") to
enable US companies to satisfy the requirement under
European Union law that adequate protection be given to
Personal information transferred from the EU to the United
States. The EEA also has recognized the US Safe Harbor as
providing adequate data protection (OJ L 45, 15.2.2001,
p.47). Consistent with its commitment to protect Personal
privacy, Walton Construction adheres to the Safe Harbor
Principles.
Walton
Construction has a Chief Privacy Officer who is responsible
for Walton Construction compliance with and enforcement of
this Policy. Walton Construction also has a Global Director
of Data Protection who assists in ensuring compliance with
this Policy and data security issues. Walton Construction
educates its employees concerning compliance with this
Policy and has self-assessment procedures in place to assure
compliance. Walton Construction Chief Privacy Officer Mike
Alexander and the Corporate Legal Team are available
to any of its valued employees, customers, vendors, business
partners or others who may have questions concerning this
Policy or data security practices. Relevant contact
information is provided herein.
This Policy
applies to all Personal information received by Walton
Construction in any format including electronic, paper or
verbal. Walton Construction collects and processes Personal
information concerning current and former employees and
their respective family members, as well as applicants for
employment through its Internet websites, its intranet site,
electronic mail and manually. Walton Construction is the
sole owner of information it collects from current and
former employees, applicants for employment, customers,
vendors and others. Walton Construction will not sell or
share this information with third parties in ways different
than what is disclosed in this Privacy Policy. On a global
basis, Walton Construction will, and will cause its
affiliates to, establish and maintain business procedures
that are consistent with this Policy.
Personal
information collected by Walton Construction from employees
and applicants for employment is maintained at its corporate
offices in Kansas City, MO in the United States as well as
the local office of the employee or applicant. Walton
Construction collects Personal information for, among other
things, legitimate human resource business reasons such as
payroll administration; filling employment positions;
administration and operations of its benefit programs;
meeting governmental reporting requirements; security,
health and safety management; performance management;
company network access; and authentication. Walton
Construction does not request or gather information
regarding political opinions, religion, philosophy or sexual
preference. To the extent Walton Construction maintains
information on an individual's medical health or ethnicity
(as legally required), Walton Construction will protect,
secure and use that information in a manner consistent with
this Policy and applicable law.
Personal
information collected by Walton Construction from
prospective customers, consumers, vendors, business partners
and others may be maintained at its corporate offices in
Piscataway, New Jersey or at other Walton Construction
facilities. Walton Construction collects Personal
information for, among other things, legitimate business
reasons such as customer service; product, warranty and
claims administration; meeting governmental reporting and
records requirements; maintenance of accurate accounts
payable and receivable records; internal marketing research;
safety and performance management; financial and sales data;
and contact information. All Personal information collected
by Walton Construction will be used for legitimate business
purposes consistent with this Policy.
For purposes
of this Policy, the following definitions shall apply:
"Agent"
means any third party that uses Personal information
provided by Walton Construction to perform tasks on behalf
of or at the instruction of Walton Construction.
"Walton
Construction" means Walton Construction its predecessors,
successors, subsidiaries, divisions and groups.
"Personal
information" means any information or set of information
that identifies or could be used by or on behalf of Walton
Construction to identify an individual. Personal information
does not include information that is encoded or anonmized,
or publicly available information that has not been combined
with non-public Personal information.
"Sensitive
Personal information" means Personal information that
reveals race, ethnic origin, trade union membership, or that
concerns health. In addition, Walton Construction will treat
as sensitive Personal information any information received
from a third party where that third party treats and
identifies the information as sensitive.
The privacy
principles in this Policy are based on the seven Safe Harbor
Principles.
(1) NOTICE:
Where Walton Construction collects Personal information
directly from individuals, it will inform them about the
purposes for which it collects and uses Personal information
about them, the types of non-agent third parties to which
Walton Construction discloses that information, and the
choices and means, if any, Walton Construction offers
individuals 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 Walton Construction, or as
soon as practicable thereafter, and in any event before
Walton Construction uses the information for a purpose other
than that for which it was originally collected. Walton
Construction may disclose Personal information if required
to do so by law or to protect and defend the rights or
property of Walton Construction.
(2) CHOICE:
Walton Construction will offer individuals the opportunity
to choose (opt-out) whether their Personal information is
(a) to be disclosed to a non-agent third party, or (b) to be
used for a purpose other than the purpose for which it was
originally collected or subsequently authorized by the
individual.
For
sensitive Personal information, Walton Construction will
give individuals the opportunity to affirmatively and
explicitly (opt-in) consent to the disclosure of the
information to a non-agent third party or the use of the
information for a purpose other than the purpose for which
it was originally collected or subsequently authorized by
the individual.
Walton
Construction will provide individuals with reasonable
mechanisms to exercise their choices should requisite
circumstances arise.
(3) DATA
INTEGRITY: Walton Construction will use Personal information
only in ways that are compatible with the purposes for which
it was collected or subsequently authorized by the
individual. Walton Construction will take reasonable steps
to ensure that Personal information is relevant to its
intended use, accurate, complete and current.
(4)
TRANSFERS TO AGENTS: Walton Construction will obtain
assurances from its Agents that they will safeguard Personal
information consistently with this Policy. Examples of
appropriate assurances that may be provided by Agents
include: a contract obligating the Agent to provide at least
the same level of protection as is required by the relevant
Safe Harbor Principles, being subject to EU Directive
95/46/EC (the EU Data Protection Directive), Safe Harbor
certification by the Agent, or being subject to another
European Commission adequacy finding (e.g., companies
located in Switzerland). Where Walton Construction has
knowledge that an Agent is using or disclosing Personal
information in a manner contrary to this Policy, Walton
Construction will take reasonable steps to prevent or stop
the use or disclosure. Walton Construction holds it Agents
accountable for maintaining the trust our employees and
customers place in the company.
(5) ACCESS
AND CORRECTION: Upon request, Walton Construction will grant
individuals reasonable access to Personal information that
it holds about them. In addition, Walton Construction will
take reasonable steps to permit individuals to correct,
amend or delete information that is demonstrated to be
inaccurate or incomplete. Any employees that desire to
review or update their Personal information can do so by
contacting their local Human Resources Representative.
(6)
SECURITY: Walton Construction will take reasonable
precautions to protect Personal information in its
possession from loss, misuse and unauthorized access,
disclosure, alteration and destruction. Walton Construction
protects data in many ways. Physical security is designed to
prevent unauthorized access to database equipment and hard
copies of sensitive Personal information. Electronic
security measures continuously monitor access to our servers
and provide protection from hacking or other unauthorized
access from remote locations. This protection includes the
use of firewalls, restricted access and encryption
technology. Walton Construction limits access to Personal
information and data to those persons in Walton Construction
organization, or as agents of Walton Construction, that have
a specific business purpose for maintaining and processing
such Personal information and data. Individuals who have
been granted access to Personal information are aware of
their responsibilities to protect the security,
confidentiality and integrity of that information and have
been provided training and instruction on how to do so.
(7)
ENFORCEMENT: Walton Construction will conduct compliance
audits of its relevant privacy practices to verify adherence
to this Policy and the US Department of Commerce Safe Harbor
Principles. Any employee that Walton Construction determines
is in violation of this Policy will be subject to
disciplinary action up to and including termination of
employment.
Any
questions or concerns regarding the use or disclosure of
Personal information should be directed to the Solutions On
Demand Inc. Privacy Office at the address given below.
Walton Construction will investigate and attempt to resolve
complaints and disputes regarding use and disclosure of
Personal information in accordance with the principles
contained in this Policy. For complaints that cannot be
resolved between Walton Construction and the complainant,
Walton Construction has agreed to participate in the dispute
resolution procedures of the panel established by the
European data protection authorities to resolve disputes
pursuant to the Safe Harbor Principles.
Walton
Construction sees the Internet, intranets and the use of
other technologies as valuable tools for communicating and
interacting with consumers, employees, vendors, business
partners and others. Walton Construction recognizes the
importance of maintaining the privacy of Personal
information collected through websites that it operates.
Walton Construction sole purpose for operating its websites
is to provide information concerning products and services
to the public. In general, visitors can reach Walton
Construction on the Web without revealing any Personal
information. Visitors on the Web may elect to voluntarily
provide Personal information via Walton Construction
websites but are not required to do so. Walton Construction
collects information from visitors to the websites who
voluntarily provide Personal information by filling out and
submitting online questionnaires concerning feedback on the
website, requesting information on products or services, or
seeking employment. The Personal information voluntarily
provided by website users is contact information limited to
the user's name, home and/or business address, phone numbers
and email address. Walton Construction collects this
information so it may answer questions and forward requested
information. Walton Construction does not sell or share this
information with non-agent third parties.
Walton
Construction may also collect anonymous information
concerning website users through the use of "cookies" in
order to provide better customer service. "Cookies" are
small files that websites place on users' computers to
identify the user and enhance the website experience. None
of this information is reviewed at an individual level.
Visitors may set their browsers to provide notice before
they receive a cookie, giving the opportunity to decide
whether to accept the cookie. Visitors can also set their
browsers to turn off cookies. If visitors do so, however,
some areas of Walton Construction websites may not function
properly.
Few, if any,
of Walton Construction websites are directed toward
children. Nevertheless, Walton Construction is committed to
complying with applicable laws and requirements, such as the
United States' Children's Online Privacy Protection Act
("COPPA").
Walton
Construction website users have the option to request that
Walton Construction not use information previously provided,
correct information previously provided, or remove
information previously provided to Walton Construction Those
that would like to correct or suppress information they have
provided to Walton Construction should forward such
inquiries to:
Walton
Construction Privacy Inquiries
Corporate Marketing
3252 Roanoke
Kansas City, Missouri 64111
Phone: 816-753-2121
Fax: 816-753-6161
The inquiries
should include the individual's name, address, and other
relevant contact information (phone number, email address).
Walton Construction will use all reasonable efforts to honor
such requests as quickly as possible.
Walton
Construction websites may contain links to other "non-Walton
Construction" websites. Walton Construction assumes no
responsibility for the content or the privacy policies and
practices on those websites. Walton Construction encourages
all users to read the privacy statements of those sites;
their privacy practices may differ from those of Walton
Construction.
The
practices described in this Policy are current Personal data
protection policies as of June 18, 2004. Walton Construction
reserves the right to modify or amend this Policy at any
time consistent with the requirements of the Safe Harbor
Principles. Appropriate public notice will be given
concerning such amendments. |
