Data Holdings Privacy Policy

Data Holdings is dedicated to providing superior customer satisfaction and to safeguarding personal information about our clients and employees.

We will use your Confidential Personal Information only in ways, that are compatible with the purposes for which we collected it from you or which you subsequently authorized, and we will provide you with notice before we use or disclose your information for a purpose other than that for which it was originally collected. We will take reasonable steps to ensure that all Confidential Personal Information we collect, retain, or use is relevant to its intended use, accurate, complete, and current.

When we host data for customers, we start with two simple principles:

• We use and otherwise process personal data only to provide the services requested by our customer.
• We maintain robust security to protect it against unauthorized acquisition or use.

Data Holdings’ obligations with respect to personal data and Intellectual Property for which Data Holdings is a data processor, such as data that Data Holding hosts for its customers are further defined in Data Holdings’ agreements with its customers. Personal information obtained from our clients is processed in compliance with the terms and conditions set forth in our client contracts and correspondence and our professional standards.

Data Holdings recognizes that its commercial customers may also be subject to detailed privacy and information security regulations as a financial institution under the Gramm Leach Bliley Act or as a covered entity or business associate under HIPAA. We can readily accommodate legal requirements to ensure appropriate privacy controls, and we enter into additional agreements, such as Business Associate Agreements, when required by applicable law.

OUR COMMITMENT TO PROTECTING CUSTOMER PRIVACY

By subscribing to our services or accessing our Web sites, you agree to our collection, use, disclosure and other processing of personal data as described in this Privacy Statement.

COLLECTION OF YOUR CONFIDENTIAL PERSONAL INFORMATION

Data Holdings does not share Confidential Personal Information with any customer, partner or other entity.

When you want to set up an account with Data Holdings, in order to determine your credit worthiness, we may use some of your Confidential Personal Information to request a credit report from a credit-reporting agency based on a permissible purpose consistent with the Fair Credit Reporting Act.

We will use your Confidential Personal Information only in ways that are compatible with the purposes for which we collected it from you or which you subsequently authorized. We will take reasonable steps to ensure that all Confidential Personal Information we collect, retain, or use is relevant to its intended use, accurate, complete, and current.

For training or quality assurance, we may monitor or record our customer service calls with you.

SENSITIVE PERSONAL DATA

We do not collect sensitive personal data, including personal data about personality and private life, racial or ethnic origin, nationality, political opinions, membership of political parties or movements, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, genetic code, addictions, sexual life, property matters or criminal record (including information about suspected criminal activities). You are not required to provide any Sensitive Personal Data to use any of our services.

TECHNICAL INFORMATION

As part of network operations and when you visit a Data Holdings Web site, we may automatically collect certain information such as your domain, your IP address, and analytic information to gauge the effectiveness of our Web sites, improve our online operations, enhance your online experience with customized content, and focus our marketing efforts to better meet the needs of our customers.

We may store small data files known as cookies, or other similar technologies, on your computer or mobile browser when you visit one of our Web sites. Cookies allow us to personalize and protect your service by collecting and storing information that will identify you when you visit a Web site. Cookies also allow us to collect usage information when you visit our Web sites, including IP address, Web browser and operating system types, Web pages visited on our Web sites, time spent on our Web pages, and return visits to our Web sites.

You may be able to disable cookies on your computer; however if you do so, you may limit your experience on this Web site. You can set your browser to delete cookies or to tell you before you accept one. Look in your browser’s Options or Preferences menu for settings relating to cookies.

CONFIDENTIAL PERSONAL INFORMATION/ DATA INTEGRITY

Data Holdings uses the information collected on its Web sites to provide you with the information you requested. When you use our Web sites to order products or services, or to request information about them, we may use the information we have about you as we would use the same information obtained offline – for example, to evaluate your service needs and contact you regarding additional services you may find useful. You may also submit applications for employment online, and we will use the information you provide to consider you for employment.

We will not use your Confidential Personal Information for a purpose other than the purpose for which it was originally collected or subsequently authorized without your consent. We will not use sensitive personal information for a purpose other than the purpose for which it was originally collected or subsequently authorized unless you have provided your affirmative and express (opt-in) consent.

When you provide us with your Confidential Personal Information, we collect that data for certain purposes that are required or permitted by applicable law, and Data Holdings may access or disclose Confidential Personal Information without further notice or your consent in order to: (i) investigate, protect or defend the legal rights or property of Data Holdings, our Affiliated Companies or their employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of customers or members of the public including acting in urgent circumstances; (iii) protect against fraud or for risk management purposes; or (iv) comply with the law or legal process such as a subpoena. Data Holdings will provide its customers with prompt notice of law enforcement requests or demands for their data to the fullest extent allowed by applicable law so that the customer may assert any defenses or other legal interests that it wishes.

If Data Holdings sells all or part of its business or makes a sale or transfer of all or a material part of its assets or is otherwise involved in a merger, transfer, or liquidation of all or a material part of its business, your Confidential Personal Information may be transferred to the party or parties involved in the transaction.

If we obtain Confidential Personal Information from a Third Party, this Privacy Statement also governs our use of that information.

SHARING OF YOUR CONFIDENTIAL PERSONAL INFORMATION / ONWARD TRANSFER

We will not disclose your Confidential Personal Information without your consent outside of Data Holdings and its affiliates with any external party unless required by law.

ACCESSING YOUR CONFIDENTIAL PERSONAL INFORMATION

Data Holdings takes reasonable measures to assure that the Confidential Personal Information we use about you is reliable, accurate, complete, and up-to-date. Customers who wish to review and/or edit their Confidential Personal Information may do so by contacting us using the information listed at the end of this statement We will make reasonable good faith efforts to provide you with access to your Confidential Personal Information upon request either to correct or amend this data if it is inaccurate or incomplete or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.

We may decline to process requests for information that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Data Holdings provides customers with the ability to authorize individuals (“Authorized User”) to make inquiries, limited changes, or both, in order to maintain their account. Customers may specify the type of information and changes that the Authorized User is approved to request. Customers may add or remove an Authorized User from their account at any time.

COMMUNICATION PREFERENCES

If desired, please specify which contact methods (phone calls, mail, bills, or email messages) you would prefer that we do not use to communicate to you. Keep in mind that restricting contact methods may make it more difficult for us to keep you informed about new products and services that can be of benefit to you. You can revoke these options at any time by contacting us using one of the methods provided in this Privacy Statement.

SECURITY OF YOUR CONFIDENTIAL PERSONAL INFORMATION

Our facilities are SSAE-16 SOC 2 Type II audited to ensure our customers’ data is secure, available, and compliant up to these rigorous industry standards.

Data Holdings takes these and other reasonable technical and organizational security safeguards to protect against such risks as loss or unauthorized access, destruction, use, alteration, modification, or disclosure of Confidential Personal Information. You should understand that the open nature of the Internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended.

We restrict access to Confidential Personal Information to Data Holdings employees. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations.

We will not store Confidential Personal Information beyond what is necessary for business purposes, including for internal service evaluation and quality assurance purposes, except as otherwise required by law.

ENFORCEMENT OF THIS PRIVACY STATEMENT

Data Holdings conducts compliance audits of our relevant privacy practices to verify adherence to this Privacy Statement. Any employee that Data Holdings determines is in violation of this Statement may be subject to disciplinary action up to and including termination of employment.

Our employees, agents, and Affiliates are trained regarding their responsibilities to safeguard your privacy. They are required to adhere to a Code of Business Conduct, this Privacy Statement, and Data Holdings’ policies, which support our commitment to protecting customer privacy. If employees or Third Parties become aware of practices that raise privacy concerns, they are required to report them to their supervisors or to contact Data Holdings’ Incident Response Team.

CHANGES TO THIS PRIVACY STATEMENT

We will occasionally update this Privacy Statement to reflect changes in our services and customer feedback or in legal requirements. When we post changes to this Privacy Statement, we will revise the “last updated” date at the top of this Privacy Statement. If there are retroactive material changes to this Privacy Statement or in how Data Holdings will use your Confidential Personal Information, we will make reasonable attempts to notify you directly. We encourage you to periodically review this Privacy Statement.

DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of Confidential Personal Information should be directed to Data Holdings at the address given below. Data Holdings will investigate and attempt to resolve disputes regarding use and disclosure of personal information by reference to the principles contained in this Statement. If you are unsatisfied with the way we have responded to any concerns about our handling of personal information about you, the matter may be dealt with through the American Arbitration Association for all personal data, except that any disputes involving personal data from the European Union must follow the procedures below.

Data Holdings voluntarily complies with the EU – U.S. Privacy Shield Framework and is subject to the investigatory and enforcement powers of the Federal Trade Commission.

CONTACTING US

Data Holdings welcomes your comments regarding this Privacy Statement. If you have questions about this Privacy Statement or believe that we have not adhered to it, please contact us by writing to us at the following address:

Data Holdings Attn: Legal Dept. 3135 W. Highland Blvd., Milwaukee, WI 53208

Any questions or concerns regarding the use or disclosure of personal information should be directed to Data Holdings at the address given above.