For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, NYI or to which NYI discloses personal information for use on NYI’s behalf.
“NYI” means NYI-NY LLC, NYI-NJ LLC, NYI-Sirius LLC, its predecessors, successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of NYI to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, NYI will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
NOTICE: Where NYI collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which NYI discloses that information, the choices and means, if any, NYI offers individuals for limiting the use and disclosure of personal information about them, and how to contact NYI. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to NYI, or as soon as practicable thereafter, and in any event before NYI uses or discloses the information for a purpose other than that for which it was originally collected.
Where NYI receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
CHOICE: NYI will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, NYI will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
NYI will provide individuals with reasonable mechanisms to exercise their choices.
ACCOUNTABILITY FOR ONWARD TRANSFER:
In the event that NYI is required to disclose personal information to a third party NYI will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Where NYI has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, NYI will take reasonable steps to prevent or stop the use or disclosure.
SECURITY: NYI will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
DATA INTEGRITY AND PURPOSE LIMITATION: NYI will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. NYI will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
ACCESS AND CORRECTION: Upon request, NYI will grant individuals reasonable access to personal information that it holds about them. In addition, NYI will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete (except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.)
ENFORCEMENT AND LIABILITY: NYI will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that NYI determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
RECOURSE AND DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the NYI Privacy Team at the address given below. NYI will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy.
Adherence by NYI to these Policies may be limited (a) to the extent required to respond to lawful requests by public authorities; (b) to the extent necessary to meet national security or law enforcement requirements; and (c) to the extent expressly permitted by an applicable law, rule, or regulation.
Questions or comments regarding this Policy should be submitted to the NYI Privacy Office by mail to:
NYI Privacy Team
100 William Street, Ste. 318
New York, NY 10038
Or by e-mail at email@example.com
This Policy may be amended from time to time, without notice.
EFFECTIVE DATE: February 1, 2019
UPDATED: February 28, 2019