International Data Management, a division of Mail America Communications, Inc., an Innovairre company (hereinafter "Innovairre") respects individual privacy and values the confidence of their customers, employees, consumers, business partners and others. Innovairre strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which they do business, and prides ourselves on upholding the highest ethical standards in our business practices. This Privacy Shield Policy (the "Policy") sets forth the privacy principles that Innovairre follows with respect to personal information transferred from the European Union (EU) to the United States. Innovairre Communications is subject to jurisdiction under the US Federal Trade Commission.

PRIVACY SHIELD

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Privacy Shield Framework") to enable U.S. 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 Privacy Shield as providing adequate data protection. Consistent with its commitment to protect personal privacy, Innovairre adhere to the Privacy Shield Framework. You may review our listing on the U.S. Department of Commerce’s Privacy Shield list at: https://www.privacyshield.gov/.

SCOPE

This Privacy Shield Framework applies to all personal information received by Innovairre in any format including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, Innovairre or to which Innovairre disclose personal information for use on their behalf.

"Personal information" means any information such as contact, address, donation, relationship, and bank information as it relates to fundraising or set of information that identifies or is used by or on behalf of Innovairre to identify an individual. Personal information does not exclude information that is encoded or anonymized, 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, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual's health. In addition, Innovairre will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

"Companies" means International Data Management, a division of Mail America Communications, Inc., an Innovairre company.

PRIVACY SHIELD PRINCIPLES

The privacy shield principles in this Policy are based on the EU-U.S. Privacy Shield Framework.

NOTICE: Where Innovairre collects personal information directly from individuals in the EU, it will inform them about the type of personal information collected, the purposes for which it collects and uses the personal information, and the types of non-agent third parties to which Innovairre discloses or may disclose that information, and the choices and means, if any, Innovairre 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 Innovairre, or as soon as practicable thereafter, and in any event before Innovairre uses or discloses the information for a purpose other than that for which it was originally collected.

Where Innovairre receives personal information from their subsidiaries, affiliates or other entities in the EU, they will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

Innovairre utilizes third-party organizations (“agents”) to perform tasks on our behalf and need to share, and may internationally transfer, your information with them to provide products or services to you; for example, banking institutions for funding purposes and third party providers that need information to perform services to us. Innovairre remain liable under the EU-U.S. Privacy Shield Principles for its agents to process transferred Personal Information in a manner consistent with the Principles.

OPT-OUT/OPT-IN: Innovairre will offer individuals the opportunity to choose (opt-out) or (opt-in) 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, Innovairre 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.

Innovairre will provide individuals with reasonable mechanisms to exercise their choices.

ONWARD TRANSFER: Innovairre will obtain assurances from their 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 Privacy Shield, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding. Where Innovairre becomes aware that an agent is using or disclosing personal information in a manner contrary to this Policy, Innovairre will take reasonable steps to prevent or stop the use or disclosure.

SECURITY: Information is provided to us from our clients for the purposes of assisting them in managing their operations. Data may flow to servers in the US for client requested processing including but not limited to import processing, selection, merge purge, hygiene, as well as bulk updates. Data may be securely transferred to third parties when requested by our clients for additional processing including but not limited to mailing presort or data appends. Innovairre will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ACCESS: Upon request, Innovairre will grant individuals reasonable access to personal information that it holds about them. In addition, Innovairre will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

DATA INTEGRITY: Innovairre will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Innovairre will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

ENFORCEMENT: Innovairre will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Innovairre determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

ASSESSMENT: Innovairre will conduct an annual review to ensure adherence to the Privacy Shield framework requirements and complaint handling procedures.

TRAINING: Innovairre will ensure all personnel receive proper training in our Shield privacy policy. In-depth extensive training will be provided to all personnel who have access and work directly with data. Any employee that Innovairre determines to fail to follow policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to Innovairre's Privacy Office at the address given below. Innovairre 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.

Under certain limited circumstances, European Union individuals may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

For complaints that cannot be resolved between Innovairre and the complainant, Innovairre have agreed to participate in the DMA Privacy Shield.

Privacy Shield Line
Data & Marketing Association
225 Reinekers Lane, Suite 325, Alexandria, VA 22314

To file a complaint/inquiry: https://thedma.org/shield-complaint-form/
https://thedma.org/resources/consumer-resources/privacyshield- consumers/

AFFIRMATIVE STATEMENT: Innovairre compliesy with the EU-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Innovairre has certified that they adhere to the EU-U.S. Privacy Shield framework of notice, choice, onward transfer, security, data integrity, access and enforcement. 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 EU-U.S. Privacy Shield framework, and to view Innovairre’s certification, please visit https://www.privacyshield.gov/welcome.

LIMITATION ON APPLICATION OF FRAMEWORK

Adherence by Innovairre to the EU-U.S. Privacy Shield framework may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation. Innovairre is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the following person by mail as follows:

Innovairre Communications, LLC 
3200 W Market St Suite 302
Akron, Ohio 44333
Attention: Colin Scheule
P: 330.869.8500

CHANGES TO THIS EU-U.S. PRIVACY SHIELD FRAMEWORK

This Policy may be amended from time to time, consistent with the requirements of the EU-U.S. Privacy Shield framework. A notice will be posted on Innovairre’s web page http://www.innovairre.com/ 

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