The Brodsky Organization
Privacy Policy

Global Privacy Policy on Personal Data

Overview
In the course of conducting our information services and technology business worldwide, The Brodsky Organization collects and processes personally identifiable information of our Web site visitors. Maintaining the integrity and confidentiality of Personal Data and handling it correctly is central to the way we conduct our business activities. This policy describes how we handle Personal Data.

Personal Data is information that can be used directly or indirectly to identify a living individual. Personal Data may include sensitive categories of information, such as information that reveals racial or ethnic origin, political opinions, religious beliefs, trade union membership, health or sexual orientation (Sensitive Personal Data).

This policy applies to The Brodsky Organization Corporation and its subsidiaries, and is effective as of July 1, 2006. All employees will be required to abide by this policy.

This policy is designed to protect Personal Data in accordance with applicable law, including any agreements between The Brodsky Organization and its web visitors, users, and others who may be subjects of the Personal Data.

Privacy Principles
We will observe the privacy principles described below of Notice, Choice/Fair Processing, Access, Security/Integrity, Onward Transfer and Enforcement/Compliance in processing Personal Data.

Notice
When we collect and process Personal Data about individuals, we will make certain information available to those individuals on a reasonable and timely basis. This information will include what Personal Data is being collected, who is collecting it, how and for what purposes it is being collected, how it is being used and to whom it will be disclosed.

Choice/Fair Processing
We will process Personal Data only with consent of the individual that is the subject of said data or when such processing is permitted by applicable law.

We will not process Personal Data in a manner incompatible with the purposes for which it was originally collected unless later authorized by the subject of said data or allowed by law; we will take reasonable steps to ensure that such data is accurate, adequate, relevant and not excessive in relation to such purposes; and we will not keep such data longer than is necessary for such purposes.

We will enable individuals to choose whether their Personal Data can be disclosed to a third party for direct marketing purposes.

Access
We will allow individuals reasonable access to their Personal Data to verify, correct or delete their data, where inaccurate. We will also provide a means for individuals to exercise all other legal rights that they may have in relation to their Personal Data.

Security/Integrity
We will take reasonable security procedures through appropriate technical and organizational measures to protect against unauthorized or unlawful access or processing, disclosure, alteration, destruction or accidental loss of Personal Data.

We will utilize reasonable means to keep Personal Data: accurate, complete and current in order to protect the quality and integrity of Personal Data, however, we rely on individuals to provide all relevant information and to advise us of any changes to their Personal Data to ensure that it remains accurate, complete and current.

Onward Transfer
When we transfer Personal Data within The Brodsky Organization or to third parties (including our suppliers and business partners), we will observe the privacy principles of Notice and Choice (described above), and we will take reasonable measures to require all the recipients of such data to provide at least the same level of protection for such data as specified by the standards stated in this policy. The Brodsky Organization is not responsible for any non-conformity with those standards by third parties.”

Enforcement/Compliance
We will follow internal processes for handling complaints regarding our management of Personal Data.

We will demonstrate our compliance with this policy by:
Publishing this policy conspicuously so that it is accessible to all interested persons.

Appointing and maintaining a Privacy Officer with responsibility for developing and implementing a privacy program.

Implementing procedures to execute this policy in the conduct of our business, including training our employees in the use of such procedures and disciplining employees for failure to comply with this policy and its procedures.

At least annually, reviewing this policy to ensure that it continues to comply with prevailing privacy standards, current applicable law and regulations and existing agreements

The Brodsky Organization Web Sites
In addition to all other Personal Data handled by The Brodsky Organization, this policy applies to Personal Data collected through The Brodsky Organization Web sites.

As a convenience to our Web site visitors, we sometimes provide links to other Web sites. These linked sites are not under the control of The Brodsky Organization, and as such, we are not responsible for their content.
 

The Brodsky Organization   400 West 59th Street    New York,  NY  10019   T: 212.896.5570 F: 212.863.3095
 

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