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Privacy Policy

Refer Cleaning Services LLC., and its affiliates and subsidiaries (Refer Cleaning Service" or "we", "us", or the "Company") take your privacy seriously. This Privacy Policy explains how we collect, use, share, and protect your Personal Information. If you do not want us to handle your Personal Information in this manner, please do not use the Refer Cleaning Service Platform. Personal Information is information that could reasonably be used to identify you individually, such as your name, e-mail address, and mobile number.

This Privacy Policy explains:

  • What information we collect

  • How we use that information

  • How we may share that information

  • How we protect your information

  • Your choices regarding your Personal Information

  • How to contact us with questions about this Privacy Policy

  • Our Safe Harbor Privacy Policy

This Privacy Policy applies only to information that we collect on the websites ReferCleaning.com, (collectively, the "Site") and through the Refer Cleaning Service mobile applications, including the mobile application for service requesters and the mobile application for service professionals (the "App") (collectively the "Refer Cleaning Service Platform").

I. INFORMATION WE COLLECT

a) Information You Give Us

We collect information that you voluntarily share with us through the Refer Cleaning Service Platform.

If you are using the Refer Cleaning Service Platform to request professional services, you may give us:

  • Contact information, such as your name, physical address, telephone number, and email address

  • Information about your home, such as the number of bedrooms, the types of appliances and zip code or postal code where your home is located

  • Billing information, such as credit or debit card number, expiration date & security code and/or information regarding your PayPal, Google Wallet or other digital payment accounts

  • Ratings and reviews of the service professionals you engage through the Refer Cleaning Service Platform

If you participate on the Refer Cleaning Service Platform as a service professional, you may give us:

  • Contact information, such as your name, email address, mailing address, and phone number

  • Log-in information, including your Refer Cleaning Service Platform username and password

  • Application information, if requesting consideration to participate as a service professional through the Refer Cleaning Service Platform, such as your experience, skills, eligibility to work, and availability

  • Social Security number, if you are a service professional who wishes to participate on the Refer Cleaning Service Platform in the United States and you are selected for a background check

If you apply on the Refer Cleaning Service Platform for employment with Handy, you may give us:

  • Contact information, including your name, email address, telephone number, and mailing address

  • Resume and LinkedIn profile

More about payment card information:

Although users can submit credit card or other payment card information to pay for a service through the Refer Cleaning Service Platform, Refer Cleaning Service does not receive this information itself. Payment card information is transmitted directly to a third-party payment card processor, Stripe, through an Internet connection secured by industry-standard Secure Socket Layer (SSL) encryption technology. Stripe then communicates to Refer Cleaning Service whether your payment has cleared, but does not provide payment card information to Handy. Stripe's privacy policy is available here.

Surveys

You may, at your choice, complete surveys on the Handy Platform about, for example, your level of satisfaction with the Handy Platform, your engagement with the Handy Platform, and your awareness of Handy Platform features. In some cases, we may link the information you provide in the survey with Personal Information in your Handy account, such as your name or email address. When linked to Personal Information, your survey information becomes Personal Information too.

b) Information We Collect Through Technology

We collect information through technology to enhance our ability to serve you. When you access and use the Handy Platform, Handy and, in some cases, our third-party service providers collect information about how you interact with the Handy Platform. We describe below a few of the methods we use to collect information through technology.

When you visit the Handy Platform, we collect your Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. However, we may link the last IP address you used to access the Handy Platform to Personal Information you provide us.

We may also collect a unique identifier for your computer, mobile device, or other device used to access the Handy Platform ("Device Identifier"). A Device Identifier is a number that is automatically assigned to the device you used to access the Handy Platform. We may link the Device Identifier to other information about your visit, such as what pages you viewed, and to Personal Information you provide us, such as your name.

Do We Use Cookies?

Yes. For more information about cookies, please visit our Cookies Policy.

Web Beacons

We may include small graphic images or other web programming code, called web beacons (also known as "pixel tags", "web bugs" or "clear GIFs"), in our web and mobile pages and messages. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons help us better manage content on the Handy Platform by informing us what content is effective, monitoring how users navigate the Handy Platform, counting users of the Handy Platform, and counting how many e-mails sent by us were actually opened.

Your 'Do Not Track' Browser Setting

We do not support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser's settings to let the websites you visit know that you do not want the websites collecting your Personal Information.

We do track your online activities over time and across third-party websites or online services. For example, we use web beacons to help us determine what links or advertisers brought you to our Site. We also use third-party service providers to display advertisements to you on other websites based on your activities while on the Handy Platform.

c) Information Collected by Mobile Applications

When you use the App, the App may automatically collect and store some or all of the following information from your mobile device ("Mobile Device Information"), including, but not limited to:

  • The type of Internet browsers you use with the App.

  • Your preferred country site.

  • Your mobile operating system.

  • Your phone number or other identifiers assigned to your mobile device, including: The IP address of your mobile device, The manufacturer and model of your mobile device

We may also collect information about how you use the App, such as the amount of time you spend using the App, how many times you use a specific feature of the App over a given time period, how often you use the App, and actions you take in the App. In addition, we may gather information about the website from which you downloaded the App to help us determine what App download site is most effective (collectively"App Usage Information").

We may link your Mobile Device Information and App Usage Information to Personal Information you have provided us, in which case we will treat the combined information as Personal Information.

Location Tracking

If you are a service professional using Handy's mobile application for service professionals (the "Pro Portal"), we may collect your geographic location by using Global Positioning System (GPS) information sent to us from the Pro Portal. For more information on when this information is collected, how we use it, and with whom it is shared, services professionals should refer to the Service Professional Agreement available on the service professional portal.

We only collect location information about service professionals who have been accepted to participate on the Handy Platform and not about service requesters or about service professionals applying to participate in the Handy Platform.

d) Information You Provide About A Third Party

If you choose to use our referral service to tell a friend about the Handy Platform, we may collect your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Handy Platform. We store this information only to send this one-time email and to track the success of our referral program. We do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you refer a friend, your e-mail address may be included in the message sent to your friend.

If you are using the Handy Platform to request professional services, you may provide us ratings and reviews of the service professionals you engage through the Handy Platform.

e) Information Third Parties Provide About You

We may supplement the information we collect about you through the Handy Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google, may tell us which ads about Handy you clicked. This is often called "conversion tracking."

In addition, when third parties such as Hirease, Onfido or Checkr.com conduct background checks on service professionals, those third parties share the results of the background check with Handy.

If you login to the Handy Platform through a social networking site, such as Facebook, we may collect your Facebook authentication token and account identification number and use that information to provide you with access to your account on the Handy Platform.

If you call or text (SMS) message a service professional or service requester using the telephone number provided by Handy, Handy uses Twilio to mask your telephone number. During this process, Handy and Twilio receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties’ phone numbers, and the content of the text (SMS) messages.

If you send a message to a service professional or service requester in the App, Handy uses Layer to process the communications. During this process, Handy and Layer receive in real time and store message data, including the date and time of the message, and the content of the messages.

If you are using the Handy Platform as a service professional, we may receive information about you in the form of ratings and reviews from requestors who engaged your professional services through the Handy Platform.

We will apply this Privacy Policy to any Personal Information received from third parties, unless we have disclosed otherwise.

f) Information You Provide to a Third Party

The Handy Platform includes links from the Handy Platform to sites or applications operated by third parties ("Third-Party Sites") and plug-ins (such as Twitter buttons) from Third-Party Sites.

For example, service professionals may be directed to a Third Party Site, such as Checkr.com, Onfido.com, or Hirease.com, so that the Third Party Site can conduct a background check. The Third Party Site may ask the service professional for identifying information to conduct the background check.

Some Third-Party Sites link to Handy and share information with Handy. For example, in some cases, you can book services through the Handy Platform with one of our booking partners, such as Airbnb and Amazon. In that case, you might provide the booking information, such as your name, telephone number, email address, and booking address, to the booking partner. The booking partner might then share the necessary booking information with us. Airbnb's privacy policy is available hereand Amazon's privacy policy is available here.

Handy does not control any Third-Party Sites, and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by that site's privacy policy.

We recommend that you read the Third-Party Site's privacy policy if you choose to enter any Third-Party Site or click on a plug-in.

II. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect to serve our customers, consider applicants, market and promote our services, and improve your experience at the Handy Platform. Some examples include:

  • Scheduling, rescheduling, and cancelling services

  • Rating and reviewing service professionals

  • Providing public profiles of service professionals

  • Addressing service complaints

  • Communicating with you by email, telephone, or text message, in accordance with your wishes

  • Managing payments for services

  • Considering whether to engage service professionals on the Handy Platform

  • Evaluating job applications to work at Handy

  • Improving customer service

  • Sending you marketing and promotional emails, unless you have told us you do not want to receive such emails

  • Troubleshooting technical problems on the Handy Platform

  • Responding to questions and feedback

  • Conducting research and analysis

  • Running online or mobile sweepstakes, contents, or other promotions

  • Marketing and advertising products and services

  • Continuously evaluating and improving the online and mobile user experience

  • Preventing, discovering and investigating violations of this Privacy Policy or any applicable terms of service or terms of use for the Mobile Application, and investigating fraud, chargebacks or other matters

  • Contacting you with regard to your use of the Handy Platform and, in our discretion, changes to the Handy Platform and/or the Handy Platform policies

By using the Handy platform, you expressly consent and agree to accept and receive communications from us, including via e-mail, text message, calls, and push notifications to the cellular telephone number you provided to us. By consenting to being contacted by Handy, you understand and agree that you may receive communications generated by automatic telephone dialing systems and/or which will deliver prerecorded messages sent by or on behalf of Handy, its affiliated companies and/or Users/Professionals, including but not limited to: operational communications concerning your account or use of the Handy Platform or Services, updates concerning new and existing features on the Handy Platform, communications concerning promotions run by us and news concerning Handy and industry developments. If you wish to opt-out of promotional emails, text messages, or other communications, you may opt-out by following the unsubscribe options described below. Standard text messaging charges applied by your cell phone carrier will apply to text messages we send. You acknowledge that you are not required to consent to receive promotional messages as a condition of using the Handy Platform or the Services. You may opt-out of receiving promotional or marketing texts or calls from Handy at any time. You may also opt-out of receiving all texts or calls from Handy (including informational or transactional messages), however you acknowledge that opting out of receiving all texts may impact your use of the Handy Platform or the Services.

The information described in this section may be transferred to, or processed and stored in, the United States and other countries, which may employ greater or less restrictive data protection laws. In all cases, we will take appropriate measures to protect your personal information in accordance with the policies described herein.

Data Retention

We delete the back-ups of the databases containing your Personal Information after 9 months, unless you request that we delete it earlier.

III. HOW WE SHARE THE INFORMATION WE COLLECT

We do not sell, rent, or trade your Personal Information to third parties other than as disclosed in this Privacy Policy at the time you provide your information. The following are some of the ways we share your information:

a) Service Professional Profiles and Ratings and Reviews by Requestors

The Handy Platform may display profiles of the service professionals who participate on the Handy Platform. These profiles may include the service professional’s name, and ratings and reviews about the service professional provided by their customers. The service professional’s profile may be visible to all users of the Handy Platform.

If you provide a rating or review about a service professional, we may post your first name, the initial of your last name, and the name of your neighborhood along with your rating or review on the service professional’s profile. In addition, service professionals may use your ratings and reviews, as well as this personal information about you, in their own marketing materials.

b) Third Parties Providing Services on Our Behalf

Third party companies and individuals provide or facilitate certain aspects of the services offered through the Handy Platform on our behalf. We may provide these third-party service providers with access to your information, including your Personal Information, so that they can perform these services for us. We require these third-party service providers to provide safeguards for your Personal Information similar to the ones that we provide.

The following are some examples of how we share your information with third-party service providers.

  • We retain third-party service providers to help us perform data analytics regarding your interactions with the Handy Platform. For example, Google Analytics (privacy policy here) and Bounce Exchange (privacy policy here) may track what pages users visit on the Site, whether users use any coupon codes, and what services users request to determine how users use the Site.

  • In some cases, these third-party service providers, such as Epsilon, may in turn share your Personal Information, such as your name and email address, with other third parties for their marketing-related purposes. If you wish to opt out of having your Personal Information shared with such third parties, please emailprivacy@handy.com.

  • Service providers help us to provide functions available through the Handy Platform. For example, we may share your Device Identifier with Urban Airship so that it can help us to send you push notifications. Urban Airship's privacy policy is available here. We share your telephone number and call data with Twilio, as described in Section I(e), above, so that Twilio can mask your telephone number. Twilio's privacy policy is available here. We share your telephone number, call data, device id and other Handy account and device information with Layer, as described in Section I(e), above, to help facilitate communication using the App. Layer's privacy policy is available here.

  • We use third-party service providers to analyze your use of our App. For example, Yozio provides reports to us showing the sites from which users download our App tied to information about how you downloaded the App, such as your IP address and Device Identifier. Yozio's privacy policy is available here.

  • We may disclose your Personal Information to an attorney in the process of obtaining legal advice.

  • We use Stripe, a third-party service provider, to process any billing information, including credit card information you submit.

  • When service professionals applying to participate on the Handy Platform in the United States provide their Social Security numbers for a background check, the Social Security number is transmitted using SSL encryption to the background check service provider. Handy also securely provides U.S. service professional's Social Security numbers to the check processor.

  • If you participate in Handy Vault, Handy uses KeyCafe, a third-party service provider, to store and provide digital access for your keys to services professionals participating on the Handy platform. As part of this service, Handy will provide KeyCafe your name and your physical keys.

  • If you provide services to a customer who participates in Handy Vault, Handy uses KeyCafe, a third-party service provider, to provided digital access to the customer's keys. As part of this service, Handy will provide KeyCafe your mobile phone number.

c) If You Agree To Receive Information From Third Parties

When using the Handy Platform, you may be presented with opportunities to receive information or marketing offers directly from third parties. If you agree to share your Personal Information to receive this information or marketing offers, your Personal Information may be disclosed to such third parties. All the information you disclose to the third parties will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to sharing your Personal Information with them. If you later decide that you no longer want to receive communication from such a third party, you will need to contact that third party directly.

d) Booking Partners

We share your Personal Information with booking partners. For example, Airbnb and Amazon customers can book services through the Handy Platform from the Airbnb and Amazon sites. Upon request, we provide our booking partners with information about the services you booked through the Handy Platform.

e) Sweepstakes, Contests and Promotions

We may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the Handy Platform that may require providing Personal Information to register. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. Please read the official rules carefully. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners' list.

f) Social Network Site Authentication

If you choose to log-in to the Handy Platform through Facebook, Twitter, or another social networking site, we may share information about your account with the social networking site.

g) Administrative and Legal Reasons

Required Disclosures:

We may be required to disclose Personal Information in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.

Legal Compliance and Protections:

We may disclose account and other Personal Information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Handy, our users, or others. This includes exchanging Personal Information with other companies and organizations for fraud prevention and credit risk reduction.

h) Corporate Transactions

We reserve the right to disclose and transfer your information, including your Personal Information:

  • To a subsequent owner, co-owner, or operator of the Handy Platform or successor database.

  • In connection with a corporate merger, consolidation, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

CHILDREN'S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

We do not collect any information from anyone under 13 years of age. The Handy Platform, and products and services offered through it, are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the Handy Platform.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE/YOUR CALIFORNIA PRIVACY RIGHTS

California residents who use the Handy Platform may request that we provide certain information regarding our disclosure of your Personal Information to third parties for their direct marketing purposes. You can make such a request by e-mail to privacy@handy.com or by mail to: PO Box #1122, New York, NY 10159

IV. HOW WE PROTECT THE INFORMATION WE COLLECT

The security and confidentiality of your Personal Information is important to us. We have implemented technical, administrative, and physical security measures to protect your Personal Information from unauthorized access or disclosure and improper use.

For example, when users book services, the information they input is encrypted through SSL encryption. We do not store credit card information on our servers, and we use SSL encryption to protect your credit card information when it is transferred to our third-party payment processor. In addition, access to your Personal Information is restricted in our offices. Only employees who need the Personal Information to perform a specific job, for example, sales representatives, managers, and customer service staff, are granted access to Personal Information. All employees with access to Personal Information are kept up-to-date on our security and privacy practices. After a new policy is added, these employees are notified and/or reminded about the importance we place on privacy, and what they can do to enhance protection for our users' Personal Information.

It is important for you to protect against unauthorized access to your account password and to your computer. Be sure to log out of your account or to close your browser after you have completed your visit to our Site.

Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Information.

V. YOUR CHOICES REGARDING THE INFORMATION WE COLLECT

You may contact privacy@handy.com to update, correct, or delete your Personal Information. You may also update, correct, and delete some of your Personal Information through your account on the Handy Platform.

In addition, you may cancel or modify the email communications you have chosen to receive from the Handy Platform by following the instructions contained in emails from us.

VI. HAVE QUESTIONS?

If you have any questions about this Privacy Policy, we'll do our best to answer them promptly. Here's how to contact us:

Email: 
privacy@handy.com

Mailing Address: 
Handy Technologies, Inc. 
PO Box #1122 
New York, NY 10159

VII. OUR SAFE HARBOR PRIVACY POLICY

To provide an adequate level of protection for Personal Information received from the Member States of the European Union and the European Economic Area ("Member States") and from Switzerland, Handy Technologies, Inc., ("Handy US") adheres to the seven Safe Harbor Principles developed by the United States Department of Commerce and the European Commission and Switzerland. In addition to the provisions in this Privacy Policy, Handy US abides by the seven privacy principles derived from the Safe Harbor privacy framework when processing the Personal Information of natural persons ("Individuals") located in the Member States and Switzerland. Individuals include users of the Handy Platform, such as service requesters and service professionals. Individuals also include employees of Handy US’s affiliated companies located in the Member States and Switzerland. Please note that service professionals who provide services through the Handy Platform are independent contractors and are not employees of Handy US or employees of any of Handy US’s affiliated companies.

The seven privacy principles are described in more detail below.

To the extent that any other provision in this Privacy Policy conflicts with the seven privacy principles below, Handy US follows these seven privacy principles instead of the conflicting provision when processing the Personal Information of Individuals located in the Member States and Switzerland.

To learn more about the Safe Harbor program, and to view Handy US's certification, please visit http://www.export.gov/safeharbor/.

1. Notice

Before processing the Personal Information of any Individual who resides in a Member State or Switzerland, Handy US, or its local affiliate, provides the Individual with a notice concerning the processing of his or her Personal Information. The notices, including this Privacy Policy, are available for review on the Handy Platform and/or provided directly to the Individual.

Handy US receives the Personal Information of Handy Platform users and processes it for the purposes described in this Privacy Policy. Handy US receives the Personal Information of applicants for employee positions located in the Member States and Switzerland ("Applicants") to administer the recruitment process and, of employees, to administer the employment relationship. Examples of the purposes for which Handy collects and uses employee and Applicant Personal Information include, without limitation, recruitment; workforce management; to administer compensation, payroll, and benefits; to address various legal obligations related to the employment relationship, including discovery obligations in civil litigation; to administer training; to administer Handy US’s compliance process; and for emergency contact purposes.

The employee Personal Information that Handy US receives from the Member States and Switzerland consists largely of information provided by Applicants, such as resumes and completed job applications and information created by Handy US or its affiliates to administer the employment relationship, such as business contact information, compensation and benefits information, etc.

Handy US will not use or disclose Personal Information transferred from a Member State or Switzerland to the United States for any purpose that has not previously been disclosed to the Individual unless: (a) the Individual has received notice and an opportunity to exercise choice, as described below, with respect to such use or disclosure; or (b) applicable law permits the use or disclosure without requiring that Handy US first comply with the Notice and Choice Principles.

2. Choice: How To Opt Out Of Collection Of Your Personal Information By Handy US and Transfer To Third Parties

Handy US will offer Individuals in the Member States and Switzerland whose Personal Information has been transferred to the United States the opportunity to opt out from: (a) the disclosure of Personal Information to a non-agent third party; and (b) the use or disclosure of their Personal Information for a purpose other than the purposes for which the information originally was collected or subsequently authorized by the Individual or a compatible purpose. Handy US will provide Individuals with reasonable mechanisms to exercise their choices should such circumstances arise.

3. Onward Transfer: Third Parties To Whom We May Disclose Your Personal Information

Handy US will comply with the Notice and Choice Principles before transferring Personal Information to a third party who is not an agent of Handy US. Before transferring Personal Information to a third-party agent, such as an authorized service provider, Handy US will obtain assurances from the agent that it will process Individuals' Personal Information in a manner consistent with these seven privacy principles. Where Handy US learns that an agent is using or disclosing Personal Information in a manner contrary to these seven privacy principles, Handy US will take reasonable steps to prevent such use or disclosure.

In some cases, as described in Section III of this Privacy Policy, our third-party service providers may in turn share the Personal Information of Handy Platform users with other third parties. You can opt out of such onward transfers by emailing privacy@handy.com.

4. Security for Your Personal Information

Handy US is committed to safeguarding the Personal Information that it receives from the Member States and Switzerland. While Handy US cannot guarantee the security of the Personal Information that it receives, Handy US takes reasonable precautions, as described in Section IV, above, of the Privacy Policy, to protect the Personal Information in Handy US's possession from loss, misappropriation, and unauthorized access, disclosure and destruction. These precautions include the measures described in Section IV, above, of the Privacy Policy.

5. Data Integrity: How We Limit The Collection And Retention Of Your Personal Information

Handy US collects only Personal Information that is necessary for the purposes described in this Privacy Policy. Handy US will process Personal Information only in ways that are for, or compatible with, the business purposes for which the data was collected or that are subsequently authorized by the Individual. Handy US takes reasonable steps to ensure that the information it collects is accurate, complete, current, and reliable for its intended use. Handy US will retain Personal Information only for as long as is necessary to accomplish Handy US's legitimate business purposes or for as long as may be permitted or required by applicable law.

6. Access And Correction: How You Can Exercise Your Rights

Upon reasonable request and in accordance with applicable local law, Handy US will grant Individuals reasonable access to their Personal Information and will permit them to correct, amend or delete Personal Information that is inaccurate or incomplete. Means for exercising these rights are described in Section V of this Privacy Policy for users of the Handy Platform. Employees should contact their local manager to exercise these rights.

7. Enforcement: What To Do If You Have a Complaint

Any Individual other than an employee who has a complaint concerning Handy US's processing of Personal Information should submit the complaint to privacy@handy.com. Handy US will investigate and attempt to resolve such complaints in accordance with these seven privacy principles. Any Individual who is not satisfied with the internal resolution of the complaint may seek redress by submitting a complaint to the Council of Better Business Bureaus, Inc. by visitinghttp://www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Any employee who has a complaint concerning Handy US’s processing of Personal Information should contact privacy@handy.com. Handy US will conduct an investigation and attempt to resolve such complaints in accordance with these seven privacy principles. Any employee who is not satisfied with the internal resolution of the complaint may seek redress with the national data protection or labor authority in the country where the employee resides. In the event the employee chooses to file a complaint with a national data protection authority, Handy US will cooperate in investigations by, and comply with the advice of, competent Member State and Swiss authorities.

Handy US will conduct periodic self-assessments of its relevant practices to verify adherence to these seven Safe Harbor Privacy Principles.

PRIVACY POLICY UPDATES

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date below. If we materially change this Privacy Policy in a way that affects how we use or disclose your Personal Information, we will notify you by prominently posting a notice of such changes before making them and by stating the effective date of the changes.

Last updated: November 30, 2016

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