eMCP Privacy Policy
eMCP, LLC Privacy Policy Effective date: March 2019
- This Privacy Policy All information described in this Privacy Policy is processed by eMCP, LLC (“eMCP”, “we”, “us”, or “our”) as data controller. This Privacy Policy describes our practices related to the use, storage, and disclosure of personal information we collect from or about you when you interact with us in the course of our providing record keeping services, ancillary services, or other services provided by us or by others acting on our behalf, including when you use our website e-mcp.com (“Website”) or our EMCP App (“App”). This Privacy Policy also describes our processing of the personal data of individuals representing our business customers and suppliers. eMCP reserves the right to modify this Privacy Policy at any time and without prior notice. We will post any changes to our Website. This Privacy Policy is not a contract and does not create any contractual rights or obligations.
- How to Contact Us If you have any questions or comments regarding this Privacy Policy, please contact our Data Protection Officer at daniel@e-mcp.com.
- How Does eMCP Collect and Receive Your Information?
3.1. We collect information from you when you:
• Use or access our Website or App, such as when you complete the “user” section during the course of adding users, or while creating an account by providing your email address;
• Register, create, or modify an online or in-app account with us;
• Use any of our services, reviewing the input data, downloading data in the form of csv files, request any filtered reports, or inputting any tasks, ;
3.2. Automatic access and data collection from our App Our App may access certain device information and/or components automatically.
- How eMCP Uses Your Data
4.1. Information about you and how we use it
This section describes what information we collect about you, the purposes for which we use it, and for the purposes of the European Union General Data Protection Regulation, the legal basis pursuant to which we process the information. Please also see section 4.2 regarding information collected through our App, and section 4.6 regarding our use of sensitive types of information.
4.1.1. Information We Collect Information related to completion of maintenance, repairs, replacements, alterations, tests of conveyance equipment, whether provided through our app, online web portal, over the phone, e-mail, in person, or otherwise, including:
• your first and last name;
• date and time you record completion of tasks;
• photos, audio, and video recordings taken by you for callback records and survey notes.
• Date and time you access information on the website e-mcp.com
4.1.2. Purposes for Which We Use It
• storing maintenance history of conveyance equipment;
• track completion progress of conveyance equipment maintenance relative to a time period;
• provide callback, maintenance, repair, alteration, replacement data to conveyance equipment owners or representatives for decision making and analytics;
• ensure proper contract compliance;
• ensure maintenance is being performed
4.2. Information collected through our App We use push notification tokens in the App to send notifications to your mobile device with updates from other users working on accessible equipment in order to provide up to date status of equipment for all users. The App will activate your camera if you choose to take a picture in some functions, for example a callback or during a survey, and will store the photo for you and others to look at later.
4.3. Legal requirements and professional advice We may also use your personal information where this is necessary to comply with a reasonable request by a law enforcement or regulatory authority, body, or agency, or in the defense of legal claims. We may also use your personal information when obtaining legal and other professional advice including for audits. We consider this to be in our legitimate interest in the management of our business.
4.4. What if you do not provide information? We need your information to perform our contract with you or other customers to provide products and services, such as record keeping details. If you do not provide this information, we will not be able to enter into or perform the contract or provide the products and services.
4.5. Sensitive Information We do not collect or receive sensitive personal information, such as that relating to health, disabilities, race, ethnicity, political opinions, biometrics, or religion.
- DATA RETENTION We store your information for a minimum of five years as legally required or for so long as necessary to support business purposes described in section 4 of this Privacy Policy and consistent with our record retention policies. Our App will store user-provided data for as long as you use the related feature of the App. In general, this storage will be:
(i) at least for the duration of our relationship,
(ii) for as long as you can bring a claim against us and for us to be able to defend ourselves, and
(iii) for any period required by applicable laws and regulations.
- HOW eMCP USES COOKIES, TAGS, AND SIMILAR TECHNOLOGIES
6.1. Cookies eMCP may use cookies, tags, and other similar technologies. For simplicity, we refer to all these technologies as “cookies”. These technologies allow us to facilitate effective Website administration. We use the information we collect to enhance your visit to the Website and to provide you with information tailored to your needs.
Your Internet browser(s) will offer you the option to refuse cookies, but doing so may affect your use of some portions of eMCP’s web services. Please refer to your browser options to learn more about cookie management.
eMCP may engage in third party tracking and advertising providers to act on eMCP ‘s behalf to track and analyze your usage of our Website through the use of cookies, pixel tags / web beacons, and similar technologies. At our request, these third parties collect, and share with us, usage information about visits to our Website, measure and research the effectiveness of our advertisements, track page usage and paths followed during visits through our Website, help us target our Internet banner advertisements on our Website and on other sites, and track use of our Internet banner advertisements and other links from our marketing partners’ sites to our Website. To learn about the available mechanisms for opting out of cookies and technologies related to interest-based advertising, see the descriptions and links in the table below.
Our Website and App are not configured to read or respond to “do not track” settings or signals in your browser headings or mobile device settings, which vary by provider. In lieu of a browser- or device-based opt-out solution, we have identified in the table below certain Digital Advertising Alliance and other approved methods for placement of “opt-out” cookies. Our Website and those of our third party advertisers or other vendors are configured to read and honor these opt-out cookies, so long as they are present on your computer or device. If you delete all cookies, you will need to reset your opt-out cookies. Please be aware that Delta does not control these opt-out processes.
- With Whom Does eMCP Share Your Information? We do not sell your name or other personal information to third parties, and do not intend to do so in the future. When you use the App, a unique ID (which varies by device manufacturer and operating system) is read from or associated with your device to be used as an anonymous identifier for analytics and performance purposes. This ID might be generated by or shared with third parties providing us with analytics services.
- Correcting or Updating Your Information If you believe that any information we hold about you is incorrect or incomplete, or otherwise needs to be changed, at info@e-mcp.com about removing your name from our subscription lists.
- Your Rights This section 9 applies only to individuals in the European Union and other countries which grant the rights described here. These rights will apply only in certain circumstances.
9.1. Requesting a Copy of Your Information To the extent you are legally entitled, you can request confirmation of whether or not we process your personal information, and details of the information that we hold about you and how we use it. You also have a right to access your personal information and to be provided with a copy.
9.2. Right to Rectification of Personal Data If you believe that the personal data we hold about you is inaccurate, you may request that we correct it. You may also request us to complete personal data about you which is incomplete.
9.3. Right to Restrict Processing Of Personal Data You have the right to request that we restrict processing of your personal information where one of the following applies:
• You claim that the personal data is not accurate. The restriction will apply until we have taken steps to ensure the accuracy of the personal data.
• The processing is unlawful, but you do not want us to erase the personal data.
• We no longer require the personal data for the purposes of processing, but you still need it in connection with a legal claim.
• You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing
9.4. Right to Request Deletion of Personal Data (“Right to be Forgotten”) You may request the erasure of your personal information in certain circumstances. For example, you may request erasure if:
• The personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
• You have withdrawn your consent and we have no other legal basis for processing the personal information.
• You have exercised your right to object to processing the personal information, and we have no overriding legitimate grounds to continue processing it.
Under certain circumstances, we may refuse a request for erasure, for example, where we need to use the personal data to comply with a legal obligation or to establish, make or defend legal claims. If you exercise your right to erasure, this will potentially remove records which we hold for your benefit, such as your SkyMiles account information (including miles that may be in your SkyMiles account) and your presence on a marketing suppression list.
9.5. Right to Object to Processing of Personal Data You have a right, at any stage, to object to our using your personal information to send you marketing information. You also have the right to object to our using your personal information where our reason is based on our legitimate interests. We will have to stop processing until we can establish that we have compelling legitimate grounds which override your interests, rights, and freedoms, or that we need to continue using it for the establishment, exercise, or defense of legal claims.
9.6. Right to Data Portability This right applies where:
• Our reason for using your personal information is either that you have given consent or that the processing is necessary for us to perform a contract; and
• We process the personal information by automated means.
This is a right to receive all the personal information which you have provided to us in a structured, commonly used, and machine-readable format and to transmit this to another controller directly, where this is technically feasible.
9.7. Complaints to Regulator You have a right to complain to a supervisory authority (i.e., a regulator which oversees data protection law compliance), in particular, in the European Union country where you live or work or where you consider we have infringed on your privacy rights.
9.8. Exercising These Rights We may charge you a small administration fee to respond to your request as allowed by applicable law. In general, we do not charge any fee where the right is based on European Union law. (We can charge an administrative fee for extra copies of your information and in certain exceptional circumstances.) Where we receive a request to exercise one of these rights, we will provide information on the action we take on the request without undue delay and in any event within one month of receipt of the request. This time may be extended by a further two months in certain circumstances, for example, where requests are complex or numerous. Where we do not carry out your request, we will tell you without delay and in any event within one month of receipt of the request, and we will explain our reasons for not taking the action requested. Any request you make must be in writing and include your name and address to our Data Protection Officer by emailing us at info@e-mcp.com.
- Data Transfers eMCP is based in Preston, Iowa, USA and we may transfer personal information in compliance with applicable law to the US and other jurisdictions where eMCP provides services.
For EU Residents: Some of the countries where eMCP provides services may not have the equivalent level of data protection laws as those in your location. If we need to transfer personal data outside the EEA, we will take steps to make sure your personal data is protected and safeguarded once it leaves the EEA. In particular, we require third parties to whom we transfer your data to agree to abide by the Model Clauses approved by the European Commission and permitted under Article 46 of the European Union General Data Protection Regulation (“GDPR”). If you would like to obtain the details of such safeguards, you can request them from the Data Protection Officer at info@e-mcp.com. In some limited circumstances, we may also transfer your information outside the EEA if the GDPR (under Article 49) allows this. This includes where it is necessary for the performance of a contract between us and you and where the transfer is necessary in connection with legal proceedings.