SNHA, A Woolpert Company Privacy Policy

1. Our Commitment to Privacy

We, SNHA, being the owner and operator of the following website: www.snh-a.com, respect the privacy of your information. These websites are referred to in this Privacy Policy as “our website” or “our site.” We provide this explanation about our online information practices as a show of our commitment to protecting your privacy.

We do not sell or rent personally identifying information collected during your use of our website without your permission.

In accordance with this Privacy Policy or otherwise upon notification to you at the time of data collection or transfer, we may share your personally identifying information with a third party. You will always have the option of not permitting the transfer by not using the particular services for which the information is collected or shared.

2. The Information We Collect

At the time you register on our site or otherwise provide information to us through our site, we may collect and store your name, email address, mailing address and other personally identifying information. The user information we collect is categorized as follows:

• Application information: Information that you provide to us through our website and other means. Examples include your email address, mailing address and phone number.
• Transaction and experience information: Information about your transactions with us, as well as information about our communications with you. Examples include your account history, requests for information and our responses.

We need this information to provide goods and services that you request from our website and to let you know of additional goods and services about which you might be interested. We also use this information to customize your experience using our website.

We may also share the information we collect about you with third parties from one or more of the following categories, but only to the extent authorized by you, necessary to provide the goods or services you request or as required by law.

• Social media companies
• Retailers
• Credit card companies
• Payment processor companies
• Banks
• Government agencies

We may ask you for personally identifying information at other times, such as if you enter into a promotion, post information, register for a forum, complete a survey or otherwise communicate with us. If you let us know that you want to receive information regarding a promotion or other service offered by a third party, you give us your permission to share your name and email address with the third party offering the promotion or other service.

In addition, we automatically gather general statistical information about our website and visitors, including (but not limited to) IP addresses, browsers, pages viewed, number of visitors, and goods and services purchased. In doing so, we do not reference you by individual name, email address, home address or telephone number. We use this data in the aggregate to determine how much our visitors use parts of our site so that we may improve our site. We may provide this statistical information to third parties, but when we do so, we do not provide personally identifying information without your permission.

As part of our service, we use cookies and beacons to store and sometimes track information about you. Some features of our site may be available only through the use of cookies. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. A beacon is a transparent image placed on our website to monitor the behavior of a visitor to our website. Generally, we use cookies to remind us who you are and enable us to access your account information so you do not have to re-enter it. We use cookies and beacons to gather statistical information about site usage, research visiting patterns, target advertisements based on user interests, help our retail partners track visits and process orders, and track progress and participation in promotions and other services. Preferences and option configurations in your browser determine if and how cookies or beacons will be accepted. You can change those configurations on your computer. By changing your preferences, you can accept all cookies, be notified when cookies are sent, or reject all cookies. If you disable cookies, you may be required to enter your information more frequently, and certain features of our site may be unavailable. Disabling cookies will also prevent beacons from tracking your unique information when visiting our website.

In addition, our retail partners, advertisers and other third parties appearing at our site or linked to our site may use their own cookies and beacons and may collect personally identifiable information, including credit card information, in connection with your use of their websites. The privacy policy of such third parties may differ from ours. We encourage you to read the third party’s privacy policy before responding to the offer to determine how the personally identifiable information is used by that third party.

Our site does not engage in the collection of personally identifiable information from users across third-party websites or third-party online services or applications, except as specified by you when you elect to register and log in to our site, via certain third-party sites or applications, such as Google+, Facebook or Twitter. Aside from the foregoing, we do not knowingly enable other parties to collect personally identifiable information about our users’ activities over time and across different sites, applications or services. If your browser or similar mechanism gives our site a “do not track” signal, our site will make commercially reasonable attempts to honor your settings (although we still may deliver and use cookies and other tracking technologies for non-marketing purposes). However, we do not make any promises or guarantees about the effects of any “do not track” choice that you may make because: (a) such nuanced treatment is not necessarily available or effective for all browsers, mechanisms or tracking technologies, and our commercially reasonable attempts to honor your settings might not be effective to preclude tracking or behavioral advertising at all or over any particular period of time; (b) third parties may not honor your settings or our policies and may use cookies or other tracking technologies for behavioral advertising despite our commercially reasonable attempts to prevent them from doing so; and (c) tracking technologies, browsers and access devices may change from time to time and our commercially reasonable attempts might not be effective for each technology or across all platforms.

3. The Way We Use Information

We use your personally identifying information to improve our marketing and promotional efforts, statistically analyze site usage, improve our content and product offerings, and customize our site’s content, layout and services.

We may use your information to deliver information to you that, in some cases, is targeted to your interests, such as articles, targeted banners, new services, advertisements and promotions. You can opt out of receiving this information by so indicating in your registration or preferences file or otherwise notifying us in writing. We may ask you to provide us voluntarily with additional information regarding your personal or business interests, experience or requests, which we may use to customize our services for you.

We may use your email address, mailing address and phone number to contact you regarding administrative notices and communications relevant to your use of our site.

If you place a request for goods or services, we use your information to deliver your order. Payments for goods and services ordered from us through our site are handled by a third-party provider. This provider, as well as other providers, may collect additional information, including billing information, credit card number, expiration date and security code, and tracking information from checks or money orders. If you obtain goods or services directly from one of our retailers or service providers, we may exchange with that retailer or provider personally identified information about you for purposes of your transaction.

We may also use or disclose information to resolve disputes, investigate problems or enforce our Website User Agreement (Terms of Use). At times, we may review the status or activity of multiple users to do so. We may disclose or access information whenever we, in good faith, believe that the law so requires, or if we otherwise consider it necessary to do so to maintain service and improve our goods and services.

We use your IP address to help diagnose problems with our server, manage our website and enhance our site based on the usage pattern data we receive.

4. Security

We employ reasonable and current security methods to prevent unauthorized access, maintain data accuracy and ensure correct use of information.

To use some of our services, you may be required to set up a password-protected account or profile on our website.  We recommend that you do not divulge your password to anyone. It is your responsibility to keep your password protected. Our personnel will never ask you for your password in an unsolicited phone call or email. Remember to sign out of your account, close your browser window and delete your temporary internet files when you have finished your session. This helps ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place where others may have access to it.

Whenever you voluntarily disclose personal information online, for example, on message boards or blogs, through email or in chat areas, that information can be collected and used by others.

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.

5. International Users

We maintain information in the United States of America and in accordance with the laws of the United States, which may not provide the same level of protection as the laws in your jurisdiction. By using our website and providing us with information, you understand and agree that your information may be transferred to and stored on servers located outside your resident jurisdiction, and to the extent you are a resident of a country other than the United States, that you consent to the transfer of such data to the United States for processing by us in accordance with this Privacy Policy.

We participate in and have certified our compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, 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 website located at https://www.privacyshield.gov/list. We are responsible for the processing of personal data we receive, under the Privacy Shield Framework, and subsequently transfer to a third party acting as an agent on our behalf. We comply 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, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we 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://www.jamsadr.com/eu-us-privacy-shield.  Under certain conditions, which are more fully described on the Privacy Shield website located at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

6. European Union GDPR Rights

We have summarized certain rights that you may have under the European Union General Data Protection Regulation 2016/679 (GDPR) if you are a data subject covered by the GDPR. Some aspects of GDPR are complex and not all of the details have been provided below. Therefore, you should read the GDPR and relevant guidance from the applicable regulatory authorities for a full explanation of these rights.

Your principal rights under GDPR are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent.

You have the right to confirm if we process your personal data, and when we do, access to that data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. While providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate personal data about you rectified, and taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of GDPR; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise, or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent; for the establishment, exercise, or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us via any of the contact information described in Section 6.

7. California Residents: Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request from us certain information regarding the disclosure of certain categories of personal information to third parties for their direct marketing purposes within the immediately preceding calendar year. A company may also comply with the law by disclosing in its privacy notice that it provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties’ direct marketing purposes (as we do), and information on how to exercise that choice.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to us via the email address or the mailing address set forth in Section 6. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state and zip code. We are not responsible for notices that are not labeled or sent properly or do not have complete information.

If you are a California resident under the age of 18, and a registered user of our website, California Business and Professions Code Section 22581 permits you to request and obtain removal of content that you have publicly posted.  To make such a request, please send an email with a detailed description of the specific content to us via the email address set forth in Section 6. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information that you have posted and there may be circumstances in which the law does not require or allow removal even if requested.

8. How You Can Update, Correct or Delete Your Information

You can access the information that we collect online and maintain through normal updating methods. To update, correct, or delete this information, you can contact us via email at social@woolpert.com, by fax at 937.461.0743, by phone at 800.414.1045, or by mail at 4454 Idea Center Boulevard, Dayton, OH  45430. Your account can be deleted or deactivated, but doing so will result in your not being able to access certain services. During the normal course of doing business, we will continue to share your information among our business units, affiliates and unaffiliated third parties as necessary to service your accounts and fill any orders you place with us.

9. Children Under 13

We have no way of distinguishing the age of individuals who access our website, and so we carry out the same Privacy Policy for individuals of all ages. If a child has provided us with personally identifying information without parental or guardian consent, the parent or guardian should contact us to remove the information and opt out of promotional opportunities or other applicable services.

10. Changes to Our Policy

Any changes to our Privacy Policy will be communicated through our website at least 30 days in advance of its effective date. Information collected before changes are made will be secured according to the previous Privacy Policy.

11. Your Consent

By using our website, you consent to the collection and use of this information in the manner described in this Privacy Policy.