We may collect, use and are responsible for certain personal information about you. When we do so, depending on from whom this information is collected, we may be subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union and the United Kingdom, and we may also be responsible as “controller” of that personal information for the purposes of those laws.
1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Milhouse Engineering and Construction, company.|
|Personal information||Any information relating to an identified or identifiable individual|
2. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
|Categories of Personal Information||Specific Types of Personal Information Collected|
|Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)||First and last name, email address|
This personal information is required to better provide our services to you.
3. How Your Personal Information is Collected. We collect most of this personal information directly from you—via our website. However, we may also collect information:
- From publicly accessible sources (e.g., property records);
- Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
- From a third party with your consent (e.g., your bank);
- From cookies on our website; and
- Via our IT systems, including:
- Door entry systems and reception logs;
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems; and
4. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To prevent and detect fraud against you||For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training, and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations|
|Statistical analysis to help us manage our business||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorized access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations|
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products|
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you|
|Marketing our services to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.||For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
|External audits and quality checks||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations|
5. Who We Share Your Personal Information With. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible.
6. Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have not sold to one or more third parties personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
In the preceding 12 months, we have not disclosed for a business purpose to third parties of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
7. Where Your Personal Information is Held. Information may be held at our offices and with third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Like us, some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard EU and UK residents’ personal information when this occurs, see below: “EU & UK Residents – Transferring Your Personal Information Out of the EEA”.
8. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy.
9. EU & UK Residents – Transferring Your Personal Information Out of the EEA. To deliver services to you, it may be necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- With our offices in the U.S.;
- With your and our service providers located outside the EEA;
- If you are based outside the EEA; or
- Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
10. EU & UK Residents – Your Rights Under the GDPR.
|Right to Access||The right to be provided with a copy of your personal information (the right of access)|
|Right to Rectification||The right to require us to correct any mistakes in your personal information|
|Right to be Forgotten||The right to require us to delete your personal information—in certain situations|
|Right to Restriction of Processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data|
|Right to Data Portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|Right to Object||The right to object: at any time to your personal information being processed for direct marketing (including profiling); In certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.|
|Right Not to be Subject to Automated Individual Decision-Making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.
11. California Residents – Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
|Disclosure of Personal Information We Collect About You||You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.|
|Personal Information Sold or Used for a Business Purpose||In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale [or disclosure] of your personal information. If you exercise your right to opt-out of the sale [or disclosure] of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale [or disclosure] of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: [URL].|
|Right to Deletion||Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.|
|Protection Against Discrimination||You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information.|
12. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- Call us, at 312-987-0061; or
- Email us at privacy [at] milhouseinc [dot] com
For California Residents – Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly by website/email/phone, you will need to provide us with:
- Enough information to identify you;
- Proof of your identity and address; and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
14. For EU & UK Residents – How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
15. Changes to This Privacy Notice. This privacy notice was published on September 1, 2022 and last updated on September 1, 2022.
We may change this privacy notice from time to time–when we do, we will inform you via our website.
WHAT KINDS OF COOKIES AND TRACKING TECHNOLOGIES DO WE USE?
PERSISTENT AND SESSION COOKIES
Cookies can remain on your device for different periods of time. We use two types of cookies:
- Persistent cookies are cookies that help us recognize you. They are stored on your device in between browser sessions, allowing us to remember your preferences and actions across multiple sites and on multiple visits.
- Session cookies expire at the end of your browser session, allowing us to link your actions during a particular browsing session.
We use Google Analytics (“Google”) as a tool to help us understand how users engage with our Websites. Like many services, Google uses first party cookies to track user interactions with website. In our case, they are used to collect information about how users use our Website. This information is used to compile reports and to help us improve our Website. The reports disclose Website trends without identifying individual visitors.
To provide you with more choice on how your data is collected by Google Analytics, Google has developed an opt-out browser add-on, which is available at https://tools.google.com/dlpage/gaoptout and enables you to opt out of being tracked by Google Analytics.
We use the following types of cookies for the reasons described below. These cookies may be set by us or a third party service provider to perform the functions described below:
- Required: These cookies and tracking technologies are required to help our Websites work correctly or required to comply with the law (e.g., security requirements of data protection law). For example, these cookies allow you to navigate our Websites and use essential features, including secure areas and shopping baskets. We do not need to obtain your consent in order to use these cookies.
- Analytics: These cookies and tracking technologies help us understand how customers and visitors interact with our Websites. They provide us with information about areas of our Websites visited, time spent on our Websites, transactions performed, and any error messages you receive. These cookies allow us to improve the performance of our Websites. They may collect your IP address but only for the purpose of identifying general locations of visitors and identifying fraudulent or spam traffic.
- Advertising: These cookies and tracking technologies allow us to deliver content, including advertisements, relevant to your specific interests. This content may be delivered on our Websites or on third party websites or services. They allow us to understand and improve the relevancy of our advertisements. They may track personal information, including your IP address.
- Functional: These cookies and tracking technologies allow our Websites to remember choices you make to give you better functionality and a personalized experience. For example, when you select a specific currency on one of our Websites, we will remember your currency selection when you return.
CHANGES TO THIS COOKIES POLICY
We will update this Cookie Notice to reflect changes in our practices and services. We recommend that you check this page from time to time to inform yourself of any changes in this Cookie Notice.