Effective Date: 9/26/16
Godfrey participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Godfrey is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Godfrey is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Godfrey complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Godfrey is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Godfrey may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Godfrey complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Godfrey has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Godfrey’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
We may collect the following personal information from you via Godfrey service or a third-party tracking company:
We use this information to:
User Data Supplementation
We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include:
Purchased marketing data about our customers from third parties that is combined with information we already have about you, to create more tailored advertising and products.
Godfrey uses a hosted email platform to power the Ingage service on behalf of its clients. When Godfrey’s Clients collect the personal information of third parties through the Ingage service, Godfrey processes this information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes.
Access and Choice Regarding Data Controlled by our Clients
Godfrey acknowledges that you have the right to access your personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Godfrey’s Client (the data controller) or in some cases Godfrey at Privacy@godfrey.com. If requested to remove data we will respond within a reasonable timeframe.
Service Provider, Sub-Processors/Onward Transfer
Godfrey may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
Godfrey will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Godfrey will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Your personal information may be available to companies that provide services to help us with our business activities. For example: Our web hosting vendors and email service providers. These companies are authorized to retain or access your personal information only as necessary to support their services to us.
Some of our pages and parts of the Ingage interface utilize framing techniques to serve content to and from our partners while preserving the look and feel of our site. Please be aware that information you provide in these areas is being shared with these third parties according to the terms and conditions of this Policy and our contracts with these partners.
We may also disclose your personal information:
As required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a government request, if Godfrey is involved in a merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information, to any other third party with your prior consent to do so.
Upon request Godfrey will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by emailing our Customer Support at Privacy@godfrey.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request within a reasonable timeframe.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
If you wish to subscribe to our newsletter, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences page on our Web site or by contacting us at Privacy@godfrey.com.
We, Godfrey and our partners use both session ID and persistent cookies or similar technologies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. These technologies are used in analyzing trends, administering the Web site, tracking users’ movements around the site and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies. If you reject cookies, you may still use our site but your ability to use some areas of our site will be limited. To manage Flash cookies, please click here.
Cookie Placed By:
Google Analytics is used through the site to capture statistical usage information used by Godfrey for internal marketing and planning purposes. Additionally cookies are used by Google to provide their Plus 1 function. More information.
You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory.
As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically collected data to personal information.
The security of your personal information is important to us. When you enter sensitive information, such as log-in credentials, we encrypt the transmission of that information using secure socket layer technology (SSL).
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at Privacy@godfrey.com.
All employees acknowledge receipt and review of our Policy and Procedure Handbook which outlines their responsibility in working with customer data.
We restrict access to customer data and customer shared data to only those employees who require the information for business purposes.
40 N. Christian St.
Lancaster, PA 17602
Phone: (717) 393-3831
Fax: (717) 393-1403