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Privacy Policy

Unique Management Privacy Policy

Effective 11/1/2019

Introduction and Scope

Unique Management Services, Inc. (“Unique”, “we”, “us”, “our”) takes the protection of personally identifiable information (“Personal Data”) very seriously. This Privacy Policy (the “Policy”) addresses data subjects whose Personal Data we may receive from our customers in providing our library material recovery services, performing outreach to library patrons, and allowing library employees to access InfoLink, our online account tracking system (collectively, the “Services”).

Controllership

Unique acts as an agent, also known as a data processor, for the Personal Data we process for our customers when providing our Services. This means that our customers determine the type of Personal Data they provide for us to process on their behalf. Any communication we establish with the individuals whose Personal Data we receive from our customers is solely at our customers’ request.

Basis of Processing

Within the scope of this Policy, we process Personal Data based on the instructions of our customers.

How We Receive Personal Data

We may receive your Personal Data when:

  • you provide it directly to us as part of using our Services;
  • your friends, family, or the postal service provide updated contact information to us; or
  • our customers (including their employees, contractors, and other representatives of the company) provide it to us.

Categories of Personal Data

We may process the following types of Personal Data:

  • biographical information, such as first and last name and date of birth;
  • contact information, such as email address, phone number, phone call recordings, and postal addresses;
  • account information, such as account number, amount owed, and whether the individual is an adult or juvenile;
  • payment information, such as a check; and
  • for library employees, we may receive first and last name and employer contact information.

Purposes of Processing

We may process your Personal Data for the purposes of:

  • recovering library materials;
  • recovering payment for missing materials or late fines;
  • sending communications to patrons asking about missing materials or account balances; and
  • allowing library employees to log in to our InfoLink portal to check the status of accounts we have been sent.

Data Retention

We retain Personal Data for as long as instructed by the respective customer (who typically acts as a data controller). We delete the Personal Data submitted to us within ninety days of receiving instruction from our customer to close the account.

 

Sharing Personal Data with Third Parties

We may share Personal Data with our service providers, who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in providing our Services or as required by law. Our service providers may provide:

  • fulfilment and postal services.

 

Some of these third parties may be located outside of the United States. However, before transferring your Personal Data to these third parties, we will either ask for your explicit consent or require the third party to maintain at least the same level of privacy and security for your Personal Data that we do. We remain liable for the protection of your Personal Data within the scope of our Privacy Shield certification that we transfer to third parties, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing.

Other Disclosure of Your Personal Data

We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for business purposes, as described in the section above.

 

We reserve the right to use aggregated, anonymous data for any legal business purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.

 

If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.

Cookies

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide website functionality, authentication (session management), usage analytics (web analytics), and to remember your settings, and generally improve our websites and Services.

 

We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our Services are first-party cookies, since they are placed directly by us. Other parties, such as Google, may also set their own (third-party) cookies through our Services. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.

 

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all of our Services’ features. For more information, please visit https://www.aboutcookies.org/.

 

You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our Services do not have the capability to respond to “Do Not Track” signals received from web browsers.

Data Integrity & Security

We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction.

Access & Review

If we process your Personal Data, you may have the right to request access to (or to update, correct, or delete) such Personal Data.

 

If we have received your Personal Data in reliance on the Privacy Shield, you may also have the right to opt out of having your Personal Data shared with third parties and to revoke your consent to our sharing your Personal Data with third parties. You may also have the right to opt out if your Personal Data is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized. Requests should be sent directly to the Unique customer who provided your Personal Data to us. Unique has limited rights to access Personal Data our customers submit to us. Therefore, if you contact us with such a request, please provide the name of the Unique customer who submitted your Personal Data to us. We will forward your request to that customer and provide any needed assistance as they respond to your request.

EU-U.S. Privacy Shield Framework

For Personal Data processed in the scope of this Policy, Unique complies with the EU-U.S. Privacy Shield Framework (the “Privacy Shield”), as adopted and set forth by the U.S. Department of Commerce regarding the processing of Personal Data transferred from the European Union, the European Economic Area, or the United Kingdom to the United States, or otherwise received in reliance on the Privacy Shield. We commit to adhere to the Privacy Shield Principles and have certified our adherence to the Department of Commerce.

 

To learn more about the Privacy Shield, and to view Unique Management Services, Inc.’s certification, please visit https://www.privacyshield.gov and https://www.privacyshield.gov/list, respectively.

VeraSafe Privacy Program

Unique is a member of the VeraSafe Privacy Program. This means that VeraSafe has assessed our data governance and data security (regarding Personal Data processed within the scope of this Privacy Policy) for compliance with the VeraSafe Privacy Program Certification Criteria. The certification criteria require that participants maintain a high standard for data privacy. Participants must also implement specific best practices regarding notice, onward transfer, choice, access, data security, data quality, recourse, and enforcement.

Dispute Resolution

Where a privacy complaint or dispute cannot be resolved through our internal processes, we have agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Privacy Shield Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

Binding Arbitration

If your dispute or complaint can’t be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you under the Privacy Shield’s “Recourse, Enforcement and Liability Principle” and Annex I of the Privacy Shield.

U.S. Regulatory Oversight

Unique is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

 

Changes to this Policy

If we make any material change to this Policy, we will post the revised Policy to this web page. We will also update the “Effective” date.

Contact Us

If you have any questions about this Policy or our processing of your Personal Data, please write to our Director of Operations by email at privacy@uniquelibrary.com or by postal mail at:

 

Unique Management Services, Inc.

Attn: Director of Operations

119 E. Maple Street

Jeffersonville, IN 47130

USA

Please allow up to four weeks for us to reply.

 

Last Edited on 2019-11-01