Effective Date of Current Policy: May 21, 2018

 

Overview

 

 

IPS–Integrated Project Services, LLC. and its operating divisions, subsidiaries, affiliates and  branches (collectively, “IPS,”  the “Company,” “we” or “us”) are sensitive to privacy issues, and it is important to us to protect  the information provided to us by our Clients, Suppliers, and potential, current and former Employees. Accordingly, IPS provides this privacy and information practices policy to inform you about our information practices, the kinds of information we may collect, how we intend  to  use and  share  that  information,  and how you can correct or change such information (“Privacy   Policy”).

 

 

This Privacy Policy applies to Personal Information that is processed by IPS in the course of our business, including on IPS’ website located at www.ipsdb.com  (together with any and all future websites operated by or on behalf of IPS, the “Sites”), and any and all future online and offline offerings operated by or on behalf of IPS (the “Services”). All individuals whose responsibilities  include  the  Processing  of Personal Information on behalf of IPS are expected to protect  that  data  by  adherence  to  this  Privacy  Policy.

 

IPS complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively “Privacy Shield”), as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of Personal Information transferred from the European Economic Area and Switzerland to the United States. IPS has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and Supplemental Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view IPS’ certification, please visit https://www.privacyshield.gov. Additionally, IPS may protect information through other legally valid methods, including international data transfer agreements.

 

This Policy applies to all IPS operating divisions, subsidiaries, affiliates and branches; including its U.S. affiliates certified under the EU-U.S. Privacy Shield Framework and any additional U.S. subsidiary, affiliate or branch of IPS that we may subsequently form. This Global Privacy Policy is designed to satisfy global and local compliance requirements; however, IPS may also maintain additional privacy  policies  and  notices  to  address  or  provide additional  details regarding certain  additional local requirements.

 

 

 

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with IPS and the requirements of applicable law. Some of the ways that IPS may collect Personal Information include:

 

• You may provide Personal Information directly to IPS through interacting with the Services, participating in surveys, during events such as sweepstakes and trade shows, and requesting Services or information.

• As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

The following sections describe who we collect information and how we use it.

 

 

IPS collects Personal Information regarding its current, prospective and former clients, customers, visitors and guests (collectively “Clients”). Client data we collect includes information  relating  to  the  sale  or support of IPS Services, including an individual’s  title,  name, address, phone number, email address, government identification (driver’s license, passport), as well as financial information related to payments for services or goods. 

 

We acquire, hold, use and Process Personal Information about Clients for a variety of business purposes including to:

 

• generally manage Client information and accounts; provide IPS International, Inc. Project Management  and  Construction  Claim Services;

• respond to questions and  requests;

• provide access to certain areas and features of the IPS’ Sites;

• verify Client identity;

• communicate about Client account and activities on IPS’ Sites and systems, and, in IPS’ discretion, changes to any IPS  policy;

• tailor content, advertisements, and offers we serve to Clients ;

• process payment for products or services  purchased;

• improve IPS Sites and systems;

• develop new products, processes and services;

• Client worker safety and/or performance using location-based technologies, tools and/or devices;

• process applications and transactions;  and

• for purposes disclosed at the time that Clients provide Personal Information or otherwise with consent.

 

 

IPS collects Personal Information regarding its current, prospective and former suppliers, distributors, subcontractors and strategic partners (collectively “Suppliers”).   Supplier information we collect relates to the management of Suppliers and the receipt of their products and services.  It may include an individual’s title, name, address, phone number,  email  address,  government  identification  (driver’s  license,  passport), as well as financial information related  to payment  for goods  and services.

 

We acquire, hold, use and Process Personal Information about Suppliers for a variety of business purposes including to:

 

• generally manage Supplier information and accounts;

• provide IPS Project Management and  Construction Claim Services;

• respond to questions and requests;

• provide access to certain areas and features of our Sites;

• verify Supplier identity;

• communicate about Supplier account and activities on our Sites and systems, and, in IPS’ discretion, changes to any IPS policy;

• tailor content;

• process payment for products or services purchased by IPS;

• improve our Sites and systems;

• develop new products, processes and services;

• process applications and transactions; and

• for purposes disclosed at the time Suppliers provide personal data or otherwise with consent.

 

 

IPS collects Personal Information from current, prospective and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include an individual’s title, name, address, phone number, email address, date of birth, passport number, driver’s license number, social security number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, contact information of third parties in case of an emergency, and beneficiaries under any insurance policy. Additionally, we may collect location information regarding our Employees, including through GPS tracking technology on Company-owned vehicles, tools or other devices. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave, as well as information relating to trade union membership.

 

We acquire, hold, use and Process Human Resources-related Personal Information for a variety of business purposes including:

 

• workflow management, assigning, managing and administering  projects;

• Human Resources administration and communication;

• payroll and the provision of benefits;

• compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with  labor laws, and company recognition programs;

• job-grading activities;

• performance and employee development management;

• organizational development and succession planning;

• benefits  and  personnel administration;

• absence management;

• helpdesk and IT support services;

• regulatory compliance;

• internal  and/or  external  or  governmental compliance investigations;

• internal or external audits;

• litigation evaluation, prosecution and defense;

• diversity and inclusion initiatives;

• shareholder management;

• restructuring and relocation;

• emergency contacts and services;

• Employee safety, including monitoring compliance with safety regulations by confirming Employees are not speeding or otherwise violating traffic laws;

• compliance with statutory requirements;

• processing of employee expenses and travel charges; and

• acquisitions, divestitures and integrations.

 

 

 

 

We endeavor to collect information only relevant for the purposes of Processing. Below are and some of the ways we collect information and how we use it.

 

 

Generally, online social media resources are interactive tools that enable Data Subjects to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards and blogs, wikis, and referral functions to share web site content and tools with a friend or colleague. IPS may collect Personal Information to enable Data Subjects to use online social media resources. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information those Third Parties share with others. IPS will only comply with the terms of this Privacy Policy and the privacy policies applicable to the social media resources it uses.

 

 

IPS may collect information about you from Third-Party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to IPS and to enhance our ability to provide you with information about our business, products and services. IPS’ agreements with these Third-Party sources typically limit how IPS may use this supplemental information.

 

 

Clients and Suppliers who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, mailings or phone calls from us with information on our products and services or upcoming special offers/events we believe may be of interest.  We offer our Clients and Suppliers the option to decline these communications at no cost to the individual Client or Supplier by following the procedures outlined below.

 

 

From time to time, IPS may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf.  All  survey responses  are  voluntary, and the information collected will be used for research and  reporting  purposes  to  help  us  to  better  serve  Clients and Suppliers by learning more about their needs and the quality of the products and services we provide.   The survey responses may be utilized to determine the effectiveness of our Sites, various types of communications, advertising campaigns and/or promotional activities.  If a Client or Supplier participates in a survey, the information given will be used along with that of other study participants.  We  may share  anonymous  individual and  aggregate  data  for  research  and  analysis  purposes.

 

 

 

 

 

IPS does not currently use cookie technology, but may in the future. Like many other websites, IPS may employ a cookie, or small piece of computer code that enables Web servers to “identify” visitors, each time an individual initiates a session on the Company’s Sites.  A cookie is set in order to identify Data Subjects and tailor our Sites to you.   Cookies do not store any of the Personal Information that is provided to the IPS Sites; they are simply identifiers. Data Subjects have the ability to delete cookie files from their own hard drive at any time. However, individuals should be advised that cookies may be necessary to provide access to much of the content and many of the features of IPS’ Sites.

 

 

IPS may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we may use "format sensing" technology, which allows pixel tags to let us know whether you received and opened our email.

 

 

Our Site includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing the features.

 

 

Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Sites. Anonymized or aggregated information is not Personal Information, and IPS may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

 

 

IPS may provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of IPS’ Sites may require that users log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, IPS may enable individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other electronic devices. These tools may transmit Personal Information to IPS to enable Data Subjects to access user accounts and to enable IPS to track use of these tools. Some of these tools may enable users to e-mail reports and other information from the tool. IPS may use personal or non-identifiable information transmitted to the Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices IPS provides.

 

 

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

 

 

You have the right to object to and opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

 

 

Where you have consented to IPS’ processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by contacting our Data Protection Officer at DPO@ipsdb.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites.

 

Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.

 

Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, IPS will endeavor to obtain each Data Subject’s explicit consent (opt-in). Where consent of the Data Subject for the Processing of Personal Information is otherwise required by law or contract, IPS will comply with the law or contract.

 

 

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding IPS and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

 

 

With regard to Personal Information that IPS receives in connection with the employment relationship, IPS will use such Personal Information only for employment-related purposes  (e.g., tax, payroll, benefits), as  more fully described in the Transparence/Notice section above. If IPS intends to use this Personal Information for any other purpose, IPS will provide the Data Subject with an opportunity to opt-out of such uses (e.g., charity, health club membership).

 

 

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

 

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. These cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device.

 

 

 

IPS does not sell or otherwise disclose Personal Information about you, except as described in this Privacy Policy or as you explicitly consent. IPS may share Personal Information with our service providers, consultants and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.   IPS requires our service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which IPS retained them. With respect to onward transfers to Agents under the US-EU Privacy  Shield,  the Privacy Shield  requires  that IPS remain liable should its Agents Process Personal Information in a manner inconsistent  with Privacy Shield  Principles.

 

We may disclose information about you: (i) if we are required to do  so  by  law,  court  order  or  legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce IPS policies or contracts; (v) to collect amounts owed to IPS; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection  with  an  investigation or prosecution of suspected or actual illegal activity; or (vii) in the good faith belief that disclosure is otherwise necessary or advisable. In addition, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Sites. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

 

We reserve the right to disclose or transfer any information we have about  you  in the event  of  a  proposed  or actual purchase, any reorganization,  sale,  lease,  merger,  joint  venture,  assignment,  amalgamation  or  any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including  in  connection  with  any  bankruptcy  or  similar  proceeding).  Should such an event occur, IPS will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy.

 

 

You agree that all Personal Information collected via or by IPS may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to IPS, you explicitly consent to the storage of your Personal Information in these locations.

 

 

Under Privacy Shield, you may seek confirmation regarding whether IPS is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete that information where it is inaccurate or has been processed in violation of the Privacy Shield Principles. Where otherwise permitted by applicable law, you may send an email to the Data Protection Officer at DPO@ipsdb.com or use any of the methods set out in this Privacy Policy to request access to, receive (port), restrict Processing, seek rectification or request erasure of Personal Information held about you by IPS. Please include your full name, email address associated with your account and a detailed description of your data request. Such requests will be processed in line with local laws. Although IPS makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which IPS is unable  to  provide  access,  including  but  not  limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden  or  expense  of  providing  access  would be disproportionate to  the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If IPS determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.   To protect your privacy, IPS will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

 

 

IPS retains the Personal Information we receive as described in this Privacy Policy for as  long as you use our Sites or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business  purposes, enforce our  agreements and comply with all applicable    laws.

 

 

The security of all Personal Information provided to IPS is important to us, and IPS takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.  

By using our Sites or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Sites. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Sites or sending an e-mail to you. You may have a legal right to receive this notice in writing.

 

Redress/Compliance and Accountability

 

If after reviewing this Privacy Policy, you would like to submit a request or you have any questions or privacy concerns about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority please contact us at:

 

IPS Attn: Data Protection Officer

721 Arbor Way, Suite 100

Blue Bell, PA 19422

USA

DPO@ipsdb.com

 

IPS will address your concerns and attempt to resolve any privacy issues in a timely manner. If you are an EU Citizen and feel that IPS is not abiding by the terms of this Policy, or is not in compliance with the Privacy Shield Principles, please contact IPS at the contact information provided above. 

 

In addition, IPS has agreed to refer unresolved complaints related to Personal Information to JAMS Privacy Shield Dispute Resolution Program and, with respect to Employee and human resources data, has committed to cooperate with the panel established by local data protection authorities and comply with the advice given by the panel for EU citizens and with the Swiss Federal Data Protection and Information Commissioner’s authority and advice for such data of Swiss citizens. For more information and to submit a complaint regarding Individual data to JAMS, a dispute resolution provider which has locations in the United States and EU, visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.

 

Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State. 

 

You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.  The FTC has jurisdiction over IPS’ compliance with the Privacy Shield.

 

 

 

Due to the nature of IPS’ business, services and benefits are not marketed to minors.  IPS does not knowingly solicit or collect Personal Information from children under the age of 13.  If you learn that your child has provided us with Personal Information without your consent, you may alert us at DPO@ipsdb.com. If we learn that we have collected Personal Information from a child under the age of 13, we will promptly delete that information.

 

 

 

Please note that our Sites may contain links to other websites for your convenience and information.  IPS does not control Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. IPS does not endorse or make any representations about Third-Party websites.  Any Personal Information you choose to give to unrelated Third Parties is not covered by this Privacy Policy. IPS encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some Third Parties may choose to share their users’ Personal Information with IPS; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

 

 

IPS may update this Privacy Policy from time to time as it deems necessary in its sole discretion.   If there are any material changes to this Privacy Policy, IPS will notify you by email or as otherwise required by applicable law. IPS encourages you to review this Privacy Policy periodically to be informed regarding how IPS is using and protecting your information and to be aware of any policy changes. Your continued relationship with IPS after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by IPS.

 

 

This Privacy Policy shall be implemented by IPS and all its operating divisions, subsidiaries and affiliates. IPS has put in place mechanisms to verify ongoing compliance with Privacy Shield Principles and this Privacy Policy. Any Employee that violates these privacy principles will be subject to disciplinary procedures.

 

 

The following capitalized terms shall have the meanings herein as set forth below.

 

“Agent” means any Third Party that processes Personal Information pursuant to the instructions of, and solely for, IPS or to which IPS discloses Personal Information for use on its   behalf.

 

“Data Subject” is an identified or identifiable natural person.

 

“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, consultant, worker or retiree of IPS or its subsidiaries worldwide.

 

“Personal Information” is any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

“Privacy Shield” means the seven (7) principles of the Privacy Shield Framework: (1) notice, (2), choice, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access, and (7) recourse, enforcement, and liability. Additionally, it includes the sixteen (16) supplemental principles described in the Privacy Shield: (1) sensitive data, (2) journalistic exceptions, (3) secondary liability, (4) performing due diligence and conducting audits, (5) the role of the data protection authorities, (6) self-certification, (7) verification, (8) access, (9) human resources data, (10) obligatory contracts for onward transfers, (11) dispute resolution and enforcement, (12) choice – timing of opt-out, (13) travel information, (14) pharmaceutical and medical products, (15) public record and publicly available information, and (16) access requests by public authorities. 

 

“Process” or “Processing” means  any operation  which  is  performed upon  Personal  Information,  whether  or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6)   health information; (7) sexual orientation or information about the individual’s sex life; or (8) information relating to the commission of a criminal offense.

 

“Third Party” is any natural or legal person, public authority, agency or body other than the Data Subject, IPS or IPS’ agents.