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NEI Customer Data Privacy and Security Policy

NEI Global Relocation Company (NEI) provides an array of relocation and assignment management services to its customers. To help facilitate a smooth relocation, NEI may receive personal, nonpublic information from you and, at times, from your employer and others, about you and your family. This policy will help you understand what types of information are needed to effectively assist you, what is done with that information, and how the information is safeguarded. By using the NEI website, you consent to the privacy practices described in this statement and agree to NEI’s terms and conditions.

Types of Information NEI May Receive

This policy covers information which can be personally identified as belonging to you and is not of a public nature. Examples of this information are Social Security numbers, bank account and routing numbers, salary and bonus information, ages, etc. NEI protects this information and your privacy by adhering to the guidelines in this Customer Data Privacy and Security Policy (Policy).

Where We Get Your Information

As part of the relocation process, we may receive personal, nonpublic information about you to provide you with various services. Most of this information will be provided by you or your employer, but it may come from other sources such as service providers involved with the sale or purchase of your home, individuals you authorized to provide us with information or other service providers.

Children – Protecting Their Privacy

The privacy and security of your children’s personal information is very important to us. Other than number of children and general ages, we do not knowingly collect information about your children. If we become aware that other nonpublic information about your children has been collected and stored in our files, we will take every precaution to maintain its privacy and to destroy it in accordance with our procedures.

How NEI Uses Your Nonpublic Information to Assist You in Relocating

To assist you in relocating, NEI works with you and other companies that perform services on your behalf. An example of this may be a moving company that would pack, store, unpack and set up your furniture and belongings in a new location.

These companies may be affiliated or non-affiliated with NEI. To provide these services to you, NEI may need to share some of your nonpublic information with those providers. NEI makes every effort to share only the information that is necessary for the provider to perform a service for you. NEI requires other companies we share your information with to safeguard your information in the same manner NEI safeguards your information. Your information will not be used, shared or sold for marketing purposes.

There are also times when NEI is required by federal and state regulators, courts and outside public accounting firms to disclose or report various aspects of your information to meet national security, regulatory, audit or law enforcement requirements. These firms, agencies and regulators are bound by regulations, nondisclosure policies, or other confidentiality provisions and are required to have security systems in place to protect your information.

Use of Cookies

A cookie, also known as a web cookie or browser cookie, is a text file that is placed on your hard disk by a web page server. Cookies are designed to receive and store website usage information such as user site activity and statistical and aggregate user data. Cookies cannot be used to run programs or deliver viruses to a computer. In an effort to better understand your use of NEI’s website and to provide a more personalized user experience, we use cookies to customize user functions, manage user preferences, and provide relevant marketing content and advertising. NEI also uses cookies and other technologies for authentication and security purposes, as well as to improve site functionality.

In addition to our own cookies, we may also use various approved third-party cookies to report usage data and statistics which will be used to deliver content and advertisements relevant to your interests based on your user activity.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. Please be aware that if you choose to decline cookies, you may not be able to fully experience the functions of the NEI website or other websites you visit.

How You Can Limit Disclosure of Your Information

You can limit disclosure of your nonpublic information by NEI to other companies by letting us know you do not want NEI to share any of your nonpublic information. This is called "opting out". You should know, however, that if you opt out, NEI may not be able to properly assist you in relocating or provide access to NEI’s website.

To "opt out" or restrict NEI's ability to disclose your information, please complete the Opt-Out Form by clicking here. NEI will then limit all of our disclosure of your information.

Safeguarding Your Information

To safeguard your information internally at NEI and any of its affiliates, we have administrative, technical and physical safeguards in place. NEI also has quality controls such as internal audits, security checks of computers and servers, policies regarding NEI personnel and their access to your data, among other security safeguards.

NEI requests suppliers delivering services to transferees to adhere to privacy laws. For your nonpublic data that may be transmitted via email or over the Internet, we use accepted industry technology and other privacy safeguard measures as noted below.

Online Privacy & Security

While visiting NEI's web site or NEI Go Mobile, our mobile application, if you give us personal data in order to receive information from us, or to provide information to us for services, we will collect and store that personal data. You then have the right to access that personal data while visiting NEI’s web site or NEI Go Mobile. The information collected by NEI's web site or NEI Go Mobile, our mobile application, is solely for the purpose of providing a service to the user.

If you view specific pages or download information from specific pages on NEI's web site or NEI Go Mobile, our mobile application, we will track and add the number of your visits to the aggregate number of visits by all users in order to better design our web site. This data is used for web site volume statistics and does not track visits on an individual basis. As we do not track visits on an individual basis, we are not able to respond to web browser “do not track” signals. We also do not knowingly allow other third parties to collect personally identifiable information about your activities while on this web site.

For your convenience, NEI’s web site and NEI Go Mobile, our mobile application, may contain access to external links or sites which NEI does NOT control. NEI is not responsible for the content contained on external links or sites. NEI does not endorse or promote the opinions, views, information, products, or services contained on external links or sites. NEI does not guarantee that the content accessed via external links or sites is correct or accurate. NEI does not guarantee that external links or sites will be uninterrupted and error-free or that such sites are free of viruses or other harmful components. Downloading, obtaining materials, information, products, software, programs, or services from external links or sites will be at your own   risk and you   will be   solely responsible for any damages that may result, including but not limited to loss of data or damage to your computer system.

NEI’s web site and NEI Go Mobile, our mobile application, take every reasonable precaution to protect our users' information. When you submit confidential information via this web site, your information is kept in a secure environment both online and off-line. Messages that you send to us by e-mail, however, may not be secure. If you choose to send any confidential information to us via e-mail, you accept the risk that a third-party may intercept and use this information.

Privacy Shield

NEI complies with the Swiss - U.S and United Kingdom (UK) Privacy Shield Frameworks (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the United Kingdom and/or Switzerland to the United States. NEI has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. In addition, NEI is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, NEI commits to resolve complaints about our collection or use of your personal information. Swiss and UK individuals with inquiries or complaints regarding our Privacy Shield policy should first contact NEI (see “Data Privacy and Security Contacts” below). Privacy Shield provides individuals in Switzerland and the UK the opportunity to limit the use and disclosure of their personal data or “opt out”. To "opt out", please click here to complete the Opt-Out Form.

NEI has further committed to refer unresolved Privacy Shield complaints to American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit American Arbitration Association for more information or to file a complaint. The services of American Arbitration Association are provided at no cost to you. To visit NEI's independent recourse mechanism, please visit http://go.adr.org/privacyshield.html.

NEI has accountability for any onward transfer of your personal data to provide you services. We will enter into contracts with third-party providers and will require that the data they receive from us may only be processed for limited and specified purposes and that they will provide the same level of protection provided under the Privacy Shield Principles. They will also be required to notify us if they can no longer meet this obligation, in which case they must cease processing, or take other reasonable and appropriate steps to protect the privacy of, your data that they hold.

Organizations that have chosen to meet the Principles, such as NEI, must allow voluntary binding arbitration for residual claims if we violate our obligations under the Principles. Under this arbitration option, an arbitration panel has the authority to impose individual-specific, non-monetary equitable relief on NEI necessary to remedy a violation of the Principles only with respect to your data. This option is available only for these purposes.

GDPR

The General Data Protection Regulation (“GDPR”), effective on May 25, 2018, was enacted by the European Commission in an effort to strengthen privacy and data protection for all individuals within the European Union (“EU”). The GDPR aims to give EU residents (“data subjects”) increased control over their personal data, as well as, provide regulatory uniformity for businesses and organizations within the EU.

The GDPR, through its “Processing Principles,” establishes the rules for the lawful transfer and processing of personal data within and outside of the EU. These principles must be followed to ensure appropriate privacy protections are provided to EU data subjects as it relates to their personal information.

The GDPR provides data subject rights to access, verify, correct, restrict transfer and use, and request erasure of their personal information. Data subjects are also granted mandatory breach notification and ready access to data breach recourse mechanisms under GDPR. To further ensure that data subject rights are adequately protected, each member state in the EU has an independent supervisory authority appointed to provide regulatory oversight and enforcement.

NEI strives to comply with all privacy and data security laws applicable to the relocation services it provides for its Clients and their employees, including but not limited to the GDPR.

NEI, which is domiciled outside of the EU, complies with GDPR by requiring that the receipt of EU personal data is done pursuant to an authorized international transfer mechanism or based on a lawful and legitimate processing purpose.

To meet the GDPR’s governance and risk assessment requirements as it relates to protecting the privacy of data subjects, NEI has implemented appropriate privacy and data security measures, such as industry standard Information Security Program which includes a privacy policy, the use of encryption and access controls, a data retention policy, an employee security training program, building security procedures, an incident tracking program for data breaches and the appointment of an internal data security and privacy officer. NEI also regularly undergoes independent audits and evaluations to assess the effectiveness of the technical and organizational measures it has in place to protect the confidentiality and security of client and user information.

NEI’s engagement of its authorized third-party service providers for processing is predicated on the third-party service provider’s commitment to adhere to GDPR and all applicable privacy or data protection regulations by implementing privacy and data security measures equivalent to those used by NEI, as applicable to the service provider’s industry. The data security programs and policies of NEI’s service providers remain subject to NEI audit, testing, and inspection to ensure appropriate safeguards, privacy protections, and data security measures are utilized and maintained during third-party processing activities.

NEI and its authorized third-party service providers are also committed to providing any necessary assistance and cooperation to its Data Controllers in their effort to demonstrate compliance to supervisory authorities and meet the GDPR’s accountability obligations to data subjects, as it relates to the data subject rights of access, erasure, breach notification and recourse.

Changes to This Policy

We will post any changes to this Policy on NEI’s web site so that you always know what information we collect and how we use it.

Data Privacy and Security Contacts

If you have any questions or concerns with your data privacy and security, please contact our Privacy Office by e-mailing NEIPrivacyOffice@neirelo.com or by calling Toll Free, 1.800.533.7353 for U.S. and Canada, or +1.402.397.8486 International.

Effective: January 21, 2021