The Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Singaporean Personal Data Protection Act (“PDPA”) and the European Union General Data Protection Regulation (“GDPR”) impose requirements regarding the collection, use, and disclosure of personal data in relation to our commercial activities, as does private-sector privacy legislation in their local jurisdictions, provinces and territories.
THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL DATA ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH A SITE OR OTHERWISE).
1. Personal Data
In this International Policy, personal data is as defined by applicable Canadian, Singaporean and European Union law. It generally means any information about an identifiable individual. It may include your name, age, mailing address, residential phone number, or e-mail address, personal history (including financial and credit information, donations, personal health information, billing history, personal family and relationship matters, and penal or criminal information), personal information related to corporate involvements, work experience (past and present), discipline, income and benefits, medical records, tax records, security clearances and computer data (IP address, geographical location, browser type, domain names, referring website addresses, access times, length of visit and number of page views).
2. Collection Of Personal Data
We collect personal data from the site(s), as well as through correspondence, faxes, live chats, e-mails, telephone inquiries, web forms, and other means of communication. We collect such information when we provide the Services and other lawful purposes.
We (and our affiliates and authorized service providers) may collect, store and use the information discussed above in WHAT INFORMATION WE COLLECT.
We also may collect information about your computer and your visits to the site(s) such as your cookie information, location pixel, browsing time, website history, internet protocol (IP) address, your login data, time zone setting and location (geocodes), geolocation data, auth0 logs, pages visited, pages viewed, events and page loads, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We may use this information in the administration of the site(s), to improve the usability of the site(s), to provide better service, to send you newsletters, updates, marketing communications, and other information that may be of interest to you. We also use outside services such Google Analytics to gather data about visitors to our site(s). We may sometimes permit our authorized service providers to have access to aggregate statistics about our customers, sales, traffic patterns, usage and related information.
We often collect personal data from you or from third-parties, and as agents on behalf of third parties, where we have obtained the requisite consent to do so or as otherwise permitted by law. Third parties include, as examples, organizations for whom we provide services to you or on your behalf (such as payment processors and systems development and maintenance organizations).
Where we are the Data Controller with regard to that data you may exercise your rights as data subject, including the right to object to the processing of your personal data when it is processed based on legitimate interests as provided in this International Policy below.
2. How We Use Personal Data
In addition to the uses described above in HOW WE USE YOUR INFORMATION, as a general matter, we collect your personal data primarily to provide services to our customers, for administrative or management requirements and to enhance our relationship with customers.
Goodway Group collects and uses your personal data to operate its site(s), deliver the Services you have requested and to provide services to our customers, including advertising services.
Goodway Group may also use your personal data to inform you of other products or services available from Goodway Group and its affiliates. Goodway Group may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
Goodway Group may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal data (e-mail, name, address, telephone number) is not transferred to the third-party. Goodway Group may share data with trusted partners to help perform statistical analysis, send you email or postal mail, or provide customer support. All such third-parties are prohibited from using your personal data except to provide services to you, and they are required to maintain the confidentiality of your data.
Goodway Group may keep track of the websites and pages our users visit within Goodway Group, in order to determine what Services are the most popular. This data is used to deliver customized content and advertising within Goodway Group to customers whose behavior indicates that they are interested in a particular subject area.
Goodway Group will disclose your personal data, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Goodway Group or the site; (b) protect and defend the rights or property of Goodway Group; and, (c) act under exigent circumstances to protect the personal safety of users of Goodway Group, or the public.
3. The Basis On Which We Process Your Personal Data
We rely on the following legal grounds to process your personal data, namely:
- Performance of a contract – We may need to collect and use your personal data to enter into a contract or to perform a contract that you or your Goodway Group has with us.
- Consent – Where required by applicable laws, we will rely on your consent for collecting your personal data.
We will only process personal data for a specific purpose or for any other purposes specifically permitted by applicable data protection legislation.
4. Obtaining Consent
Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your personal data for any purpose. You may provide your consent to us orally, in writing, by electronic communication or any other means reasonably capable of conveying your consent. We will obtain your express consent if we collect, use or disclose sensitive personal data in our capacity as a data controller. We may also share data with third-party partners for whom you have given us consent. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided personal data to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you. Except when otherwise permitted by law, we will only use the data for the purpose for which it was given. From time to time, we may collect, utilize or disclose your personal data based on your consent and as otherwise permitted by law.
When your consent is required, you may withdraw your consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations) upon providing to us a 30-day notice. However, the withdrawal of your consent may adversely affect our ability to provide Services to you and to maintain our relationship.
We remain responsible for all personal data communicated to third parties for processing. As such, we ensure that third-parties that are engaged to provide products or services on our behalf and are provided with personal data are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclose the personal data for any purpose other than the purpose for which the personal data was communicated.
We only collect the personal data necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.
We do not use or disclose your personal data, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.
We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal data beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law.
7. Retention Of Personal Data
We may keep a record of your personal data, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal data. When personal data is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies.
8. Access And Rights To Your Personal Data
Subject to the exceptions provided by the applicable law, we will make available to you any of your personal data that we have collected, utilized or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. If you are a located in the European Economic Area (“EEA”), the GDPR provides you rights of access, rectification, erasure, restriction, objection or portability in line with the type of services being provided. Simply send your request, using the Request Form provided, to the Privacy Officer listed below. Please be as specific as possible in your request so that we can meet the applicable time lines. REQUEST FORM
If you are a located in the EEA you also have the right to lodge a complaint to your Supervisory Authority.
9. Response Times
We will make every reasonable effort to respond to each of your written requests no later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority with respect to this time limit.
We expect to be able to respond to your request without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.
11. Identifying You In Connection With Requests
We may require that you provide to us sufficient information to identify yourself before we provide information about the existence, use or disclosure of your personal data in our possession. Any such information shall be used only for this purpose.
12. Opt-Out And Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving certain information. Users may opt-out of using the instructions located in e-mails sent by Goodway Group or by contacting us using the information under Contact.
We will use reasonable efforts to ensure that your personal data is kept as accurate, complete and up-to-date as possible. We will not routinely update your personal data, unless such a process is necessary. In order to help us maintain and ensure that your personal data is accurate and up to date, you must inform us, without delay, of any change in the data you provided to us.
You can at any time, challenge the accuracy or completeness of the personal data we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal data we have on you is inaccurate or incomplete, we will amend the personal data as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal data.
We use security safeguards appropriate to the sensitivity of personal data to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.
For residents of the EU and Singapore:
GSM: +31 (0)623214871
For residents of Canada:
Goodway Group, Inc.
261 Old York Road, Suite 930
Jenkintown, PA 19046
(877) 274-9881 (toll free)