Privacy Policy

GRM Website Privacy Information

GRM Information Management Systems, Inc. and its affiliates (“GRM”) are committed to protecting the privacy of its customers. We have adopted this online privacy statement to ensure that your personal information is secure and your privacy respected, and to provide you with information about what type of information is gathered and tracked on our web site, how the information is used, and with whom the information is shared. Please review the policy terms carefully before using this web site. By using this site, you are agreeing to the terms set forth below.

COLLECTION OF PERSONAL INFORMATION

In order to offer you a more consistent and personalized experience in your web site interactions with GRM, we ask you to provide personal information, such as your e-mail address, name, home or work address or telephone number. We may also collect information about your visit, including the pages you view, the links you click and other actions taken in connection with the GRM site and services. This information is collected to better enable GRM to assess your specific needs, whether answering specific questions you may have relating to GRM and the services it offers, or providing you with various materials creat ded by GRM in response to such questions. Your use of the GRM website constitutes your consent to collect the personal information you provide.
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USE OF PERSONAL INFORMATION

GRM collects and uses your personal information to operate and improve its sites, to provide information and news regarding GRM services, to deliver GRM services, or carry out the transactions you have requested. We do not share, sell or trade with third parties your personal information gathered online. We do not knowingly collect personal information from minors and ask that children under 18 years of age not submit personal information on this site without parental consent. We will only use information collected by us to respond to your inquiries and otherwise correspond with you, to process orders you have submitted, and to maintain your account. We may disclose information you provide to us to unaffiliated third parties that are contracted to perform services for or on behalf of GRM, however, such third parties are required to uphold the confidentiality of your personal information and may not use it for any purpose other than to carry out the services they are performing for GRM. We do not sell or release our customer’s personal information to outside organizations, unless to: (i) respond to duly authorized information requests of government authorities; (ii) comply with any law, regulation, subpoena or court order; (iii) help prevent fraud or to enforce or protect the rights and properties of GRM; or (iv) to protect the personal safety of GRM employees and third parties on GRM property.
GRM respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does GRM strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy Statement (the “Policy”) sets forth the privacy principles GRM follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.
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SAFE HARBOR

GRM respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does GRM strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy Statement (the “Policy”) sets forth the privacy principles GRM follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland 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 to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under
Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, GRM adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).

SCOPE

This Safe Harbor Privacy Policy Statement (the “Policy”) applies to all personal information received by GRM in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply: “GRM” means GRM, its predecessors, successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of GRM to identify an individual. Personal information does not include 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, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, GRM will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Privacy Principles

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
Where GRM receives personal information from its subsidiaries, customers, affiliates or other entities in the EEA, it 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.

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

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

Security: GRM will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: GRM will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that GRM determines is in violation of this 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 the GRM Privacy Officer at the address given below. GRM will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between GRM and the complainant, GRM has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

1. for disputes involving all personal information received by GRM from Switzerland, GRM agrees to cooperate with the Swiss FDPIC;
2. for disputes involving employment-related personal information received by GRM from the EEA, GRM agrees to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
3. For disputes involving all other personal information received by GRM from the EEA, GRM has agreed to JAMS dispute resolution services. Individuals who submit a question or concern to GRM and who do not receive acknowledgment from GRM of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the JAMS Safe Harbor Dispute Resolution Program by email. Inquiries should identify GRM as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether JAMS may share the details of the inquiry with GRM. JAMS will act as a liaison to GRM to resolve these disputes.

JAMS
JAMS International Case Manager
Telephone: (+1) 212.607.2799
Email: info@jamsinternational.com

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by GRM to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the GRM Privacy Officer by mail to:
GRM Privacy Officer
215 Coles St
Jersey City, NJ 07310

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the GRM web page (www.grmdocumentmanagement.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.
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CORRECTING/UPDATING/REMOVAL OF PERSONAL INFORMATION

If information which you have submitted to us changes, or if you no longer desire our services, you are entitled to request that GRM (i) correct any errors in your personal information; (ii) update your personal information as required; and/or (iii) cease processing your personal information, in whole or in part, as you direct us, for the purpose of direct marketing.

For any request related to personal information and requests regarding your data under the California Consumer Privacy Act (CCPA), GDPR, & forthcoming regulations, please send an email to privacy@grmdocument.com.
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SECURITY

GRM is committed to protecting the security of your personal information. We use a variety of precautions to protect information about our customers while it is stored on our servers or in transit to our vendors operating on our behalf. Sensitive information provided to us online (such as credit card numbers) is encrypted and transmitted to us securely, and access to all of our customers’ information (sensitive and otherwise) is restricted. Only employees who require the information to perform a specific job for or on behalf of GRM are granted access to personally identifiable information. In addition, the servers on which we store personally identifiable information are kept in a secure environment.
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LINKS AND THIRD-PARTY WEBSITES

For your convenience and information, our web sites contain links to third-party web sites. If you access those links, you will leave the GRM website. GRM does not control those sites or their privacy practices, which may differ from GRM’s practices.
We do not endorse or make any representations about third-party websites. The personal data you choose to reveal to unrelated third parties is not covered by the GRM Privacy Statement. We urge you to review the privacy policy of any company before submitting your personal information.
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APPLICABLE LAW

The laws of the State of New York will govern these disclaimers, terms and conditions without giving effect to any principles of conflict of law.
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CONTACTING US

GRM welcomes your comments regarding this Privacy Statement. If you have questions about this statement or believe that we have not adhered to it, please contact us by writing to the following address:
GRM Information Management Services, Inc
215 Coles Street
Jersey City, NJ 07310
Attn: Human Resources
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