Last updated – January 10th, 2019
- What data we collect, and why we collect it
- How we use that data
- How we protect that data
- How you can control your data, including accessing, updating and deleting what we store
- How we share data collected
Data We Collect & Share
RRD may collect or record basic personal data (e.g., name, e-mail address, mailing address, phone number) which you voluntarily provide through forms on our Site, through social media, subscription to our email alerts, electronic mail you send to us, or through other means of communication between you and RRD.
RRD only collects personal data of a more sensitive nature (e.g. social security or other governmental ID numbers, credit card details and account numbers) where it is appropriate or necessary for conducting business. This data will be collected, stored, accessed and processed in a secure manner. RRD may also collect general non-personal data pertaining to users of our sites, including IP addresses, source domain names, specific web pages, length of time spent, and pages accessed. This data is collected, among other things, to aggregate statistical data, facilitate system administration and improve the Site.
RRD also collects, uses, and discloses identifiable data about individual contacts for RRD’s customers (“Business Contact Data”) in the ordinary course of its business for managing and maintaining customer relationships. In particular, RRD may obtain the following types of Business Contact data: name, address, invoice data including bank account data, and order data. Unless otherwise specified or prohibited, RRD may share data with affiliates, business partners, service providers, subsidiaries or contractors who are required to provide you with services which you have requested from us.
RRD may also post links to third party websites as a service to you. These third party websites are operated by companies that are outside of our control, and your activities at those third party websites will be governed by the policies and practices of those third parties. We encourage you to review the privacy policies of these third parties before disclosing any data, as we are not responsible for the privacy policies of those websites.
RRD Employee Information:
With regard to RRD employee data, RRD collects employee data only for legitimate business purposes, including:
- Carrying out obligations under employment contracts and employment, tax and benefits laws, and in connection with other working relationships or arrangements
- Employee communications, including development and training programs
- Maintaining a global employee directory
- HR activity including:
- Managing employee compensation and performance
- Managing employee hiring (including background checks, references checks) and employee terminations
- Voluntarily obtaining employee personal data about family members, including emergency points of contact
Employee information on health, performance evaluations and other sensitive employee matters, whether it is stored manually or electronically, is accessible by other RRD employees only if necessary with respect to legitimate human resource functions or issues. Additionally, employee personal/family information is never sold, leased, or rented to any third party. RRD will obtain affirmative consent from an employee before using such employee’s personal data for any purpose other than described above.
Employee personal data will never be disclosed to third parties except as follows:
- To those retained by RRD as agents for the purposes of providing requested services to RRD
- Where required pursuant to an applicable law, governmental or judicial order, law or regulation, or to protect the rights or property of RRD
- Where the employee voluntarily provides personal data and the context makes it clear that such data will be provided to a third party.
Where human resource data is transferred from the EU to the US in the context of the employment relationship, RRD will cooperate in investigations by and to comply with the advice of the appropriate EU authorities.
How We Use data
RRD uses the data we collect to provide you with services which you request and to improve our existing services and the content of our Site. When you contact RRD, we may keep a record of your communication to help solve any issues that you might be facing. Depending on the country in which you live, work or access our Site(s), your data may be retained for a reasonable time for use in future contact with you, or for future improvements to RRD services. In the event the data you provide to us is an application for employment, that application will be held in accordance with our HR records management policy. You have the option to opt-out or opt-in for further communications from RRD.
RRD may also use or disclose your personal data when RRD believes, in good faith, that such use or disclosure is reasonably necessary to (i) comply with law, (ii) enforce or apply the terms of any of our user agreements, or (iii) protect the rights, property or safety of RRD, RRD users, or others. RRD reserves the right to transfer and disclose your data if RRD becomes involved in a business divestiture, change of control, sale, merger, or acquisition of all or a part of its business.
Cookies are a technology that can be used to help personalize your use of a website. A cookie is an element of data that a website can send to your browser, which may then store it on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or decline at any time. To enable RRD to access the effectiveness and usefulness of this Site, and to give you the best user experience, we collect and store data on pages viewed by you, your domain names and similar data. Our Site makes use of anonymous cookies for the purposes of:
- Completion and support of Site activity;
- Site and system administration;
- Research and development;
- Anonymous user analysis, user profiling, and decision-making.
In addition, in certain external facing RRD applications, you can accept or decline the use of 3rd party cookies based on your personal preferences.
The security of your personal data is important to us. We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it.
RRD uses reasonable measures to safeguard personally identifiable data, which measures are appropriate to the type of data maintained, and follows applicable laws regarding safeguarding any such data under our control. In addition, in some areas of our Sites, RRD may use encryption technology to enhance data privacy and help prevent loss, misuse, or alteration of the data under RRD’s control. RRD also employs industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our systems.
Monitoring and Enforcement
RRD adheres to US and other international regulations such as:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (for the purposes of Article 3(2) of that Regulation.
- Privacy and Electronic Communications Directive (2002/58/EC) Directives (as amended)
RRD recognizes and has controls in place to ensure that the privacy of personal data about an “identifiable individual” used in the course of “commercial activity” is protected and managed in such a manner which meets or exceeds the guidelines set out in PIPEDA and applicable provincial legislation.
Privacy Shield (European Union, Switzerland and United Kingdom)
RRD may obtain in the US the following types of EU and Swiss information: name, address, invoice information including bank account information, and order information (“EU and Swiss Business Contact Information”). RRD uses EU and Swiss Business Contact Information for the following purposes: managing customer relationships, managing orders, tracking payments and ensuring payment, and otherwise maintaining the customer relationship. RRD may disclose EU and Swiss Business Contact Information to its affiliates, subsidiaries, business partners, and service providers for the purposes listed above.
In situations where RRD discloses (ie onward transfers) EU and Swiss Business Contact Information to any third parties acting as service providers or “agents” on behalf of RRD, RRD will require the recipient to protect the disclosed EU and Swiss Business Contact Information in accordance with the relevant Privacy Shield Principles, or otherwise take steps to ensure that the EU and Swiss Business Contact Information is appropriately protected. With respect to any sharing of EU and Swiss Business Contact Information for the purposes of marketing RRD products and services, RRD obtains guarantees from its affiliates, subsidiaries and business partners that such entities will use and disclose such EU and Swiss Business Contact Information for purposes of marketing RRD products and services only. In cases of onward transfer of EU or Swiss Business Information to third parties pursuant to Privacy Shield, RRD is potentially liable in the event of an improper disclosure. In certain situations, individuals may seek to opt-out of disclosures of their EU and Swiss Business Contact Information by contacting RRD as specified in the “Contacting RRD” section below.
RRD takes appropriate technical and organizational measures to safeguard EU and Swiss personal data against unauthorized or unlawful processing of, or accidental loss, damage, misuse, unauthorized access, unauthorized disclosure, unauthorized alteration, or destruction, and maintains reasonable procedures to help ensure that such information is relevant for its intended use, accurate, complete, current and not excessive and that such information is not retained longer than is reasonably necessary.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, RRD is subject to the regulatory enforcement powers of the United States Federal Trade Commission. In certain situations, RRD may disclose EU and Swiss personal data as necessary in connection with the sale or transfer of all or part of its business, where required or permitted by law, where RRD believes that such disclosures are appropriate in connection with a law enforcement request or as otherwise permitted by the Privacy Shield Principles, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud or in order to comply with, enforce or apply RRD agreements.
In compliance with the Privacy Shield Principles, RRD commits to resolve complaints about our collection or use of your personal data at no cost to the individual. European Union and Swiss individuals with inquires or complaints regarding our Privacy Shield policy should contact the RRD Privacy Shield point of contact – IT Governance Director – Europe at DataPrivacyEurope@rrd.com. RRD will respond to your inquiry within 45 days.
In the event of a reported complaint that RRD does not resolve itself, RRD commits to cooperate with the EU Data Protection Authorities (DPA’s) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by the EU DPA panel or Swiss Commissioner with regard to human resource and non-human resource data transferred from the EU and Switzerland to RRD in the United States (US).
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Data Processor Activities
RRD operates as a data processor for our business customers located in the US, EU and other geographic locations worldwide. RRD’s business customers remain the data controllers with respect to any Customer data that they provide to RRD for our provision of services. RRD therefore acts in accordance with the instructions of such customers regarding the collection, processing, storage, deletion and transfer of Customer data, as well as other matters such as the provision of access to and rectification of this Customer data.
Children’s Online Privacy Protection – COPPA
RRD does not sell its services to children. As such, our Sites are designed for adult user interaction. We do not intentionally collect personally identifiable data from children under the age of 13.
Accessing and Updating Your Personal Data
If you have provided RRD with your personal data you have various rights:
- If you are a data subject based in the EU (and to the extent that Article 3(2) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 applies to you) and where we control your data you have the right:
- (in certain circumstances) to erasure of personal data (and to therefore be forgotten);
- to data portability;
- to launch a complaint with the office of the Information Commissioner;
- to inspect the data stored by RRD for accuracy;
- to have the option to opt-out or opt-in for further communications from RRD
- via Subject Access Request, to know whether or not we are processing your personal data, the nature of that personal data and the purposes of the processing.
- Where the above does not apply to you, you may have the right to inspect the data stored by us for accuracy, or may request that the data be removed from our files. RRD will make a reasonable effort to comply with such requests except where it would require a disproportionate effort (for example developing a new system or changing an existing practice). We may require that you verify your identity before we act on a request to edit or remove your data. Please direct any questions about your data to RRD by sending on inquiry to the appropriate contact in the “Contacting RRD” section below.
In the EU, please direct questions to the IT Governance Director/EU Data Protection Officer – DataPrivacyEurope@rrd.com.
In the Philippines, please direct questions to the Data Protection Officer – Philippines at DataPrivacyPH@rrd.com.