Donnelley Financial is a global organization with legal entities and business processes in operation across borders. Donnelley Financial complies with the EU-U.S. Privacy Shield Framework and the Swiss–U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data transferred from the European Union (EU) and Switzerland to the United States, respectively.
Donnelley Financial has certified to the Department of Commerce that is adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability. Donnelley Financial is accordingly subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
If there is any conflict between the terms of this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the Department of Commerce’s Privacy Shield Website at https://www.privacyshield.gov/.
With respect to any sharing of EU and Swiss Business Contact Information for the purposes of marketing Donnelley Financial products and services, Donnelley Financial obtains assurances 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 Donnelley Financial products and services only.
In cases of onward transfer of EU or Swiss Business Information to third parties pursuant to Privacy Shield, Donnelley Financial 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 Donnelley Financial as specified in the “How To Contact Us” section below.
Donnelley Financial 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, Donnelley Financial is subject to the regulatory enforcement powers of the United States Federal Trade Commission. In certain situations, Donnelley Financial 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 Donnelley Financial 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 Donnelley Financial agreements.
In compliance with the Privacy Shield Principles, Donnelley Financial 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 inquiries or complaints regarding our Privacy Shield policy should contact the Director of Global Data Privacy at firstname.lastname@example.org. Donnelley Financial will respond to your inquiry within 45 days.
In the event of a reported complaint that Donnelley Financial does not resolve itself, Donnelley Financial commits to cooperate with the EU Data Protection Authorities (DPAs) 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 Donnelley Financial 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.