Effective Date: 09/25/2018
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
CORT Business Services Corporation participates in and has certified its 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, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]
CORT Business Services Corporation is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. CORT Business Services Corporation complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, CORT Business Services Corporation is 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.
1. The Information We Collect.
We collect and maintain different types of personal information that you and/or your employer provide to us on a voluntary basis. This may include:
• Personal information such as given name(s), preferred name(s), gender, marital status;
• family information such as names and contact details of spouses and dependents;
• contact information such as address, telephone/mobile number, email address; employment information such as role/title, name of current employer, work address, work telephone, work email address, fax number;
• product and service related information concerning the products and services that we provide to you or programs that we offer;
• for parties with whom we do business, credit and financial information such as your payment methods and preferences, and billing and credit history, where applicable; and
• business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and information requested by or provided to you.
If you email us a question or request, we may use your email address to process your request and respond to your question.
2. How We Collect Personal Information
In order to provide relocation services, CORT receives information about you from your employer, and collects information directly from you for that purpose. In addition to this direct contact with you and your employer, CORT also collects information through the following methods:
Throughout our websites, we have provided Site visitors various forms from which they can request additional information about CORT products and services, or from which they can request to speak with a CORT customer service representative. On these forms, visitors are prompted to provide their names, contact information and, in some cases, other personally identifiable information pertinent to the request.
We also collect information about the nature of your use of the Site. We collect this information and use it in the aggregate to monitor the Site, to improve Site offerings and for targeted promotional or marketing initiatives. Aggregated data are compiled into statistical and demographic information that we use, and may share with others, to show preferences of Site users in the aggregate, but not the preferences of any individual users. If we share this kind of aggregated data with third parties, it will not include a level of detail that would permit a third party to associate an individual user with the user's usage or preferences. We may combine autonomous information with personally identifiable information to identify a user in order to enforce the Website Terms & Conditions.
We collect your location based information for the purpose of locating a place that you may be searching for in your area. We will only share this information with our mapping provider for the sole purpose of providing you this service. You may opt-out of location based services at any time by emailing us at email@example.com
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. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at PrivacyQA@cort.com and include the CORT domain at issue.
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: Company, Occupation, Job Title, Mailing Address.
3. How We Use the Information We Collect
We use the personally identifiable information we collect on the Site to ensure compliance with the website Terms & Conditions, to offer and render our services and to respond to our users' queries. We also use personal information from you to enable us to manage, maintain, and develop our business and operations, including:
• to establish, maintain and manage our relationship with you so that we can provide the programs, products and services that have been requested;
• to be able to review the products and services that we provide to you so that we may understand your requirements for our programs, products and services and so that we may work to improve our products and services;
• to administer or otherwise carry out our obligations in relation to any agreement you or your employer have with us;
• to protect us against error, breach of contract, negligence, fraud, theft, illegal activity and damage to our goods and property;
• to alert you to updated information and other new products and services from us, or third-parties, or to forward promotional materials to you, where you have consented to receive such information;
• to complete a transaction or service requested by you or your employer;
• to respond to inquiries or requests submitted by you or your employer;
• to ensure the Sites are relevant to your needs;
• to help us create and publish content most relevant to you;
• to enable us to comply with applicable law or regulatory requirements; and
• any other reasonable purpose to which you consent.
Personally identifiable information is accessible by our employees, contractors and agents to the extent reasonably necessary for these purposes. In addition, we also use this information to generate a list of email addresses to which we send correspondence from CORT Business Services. Such correspondence may include occasional updates about our products and services, invitations to attend CORT events and to visit our booths at relevant trade shows and information relevant to any business that you may choose to do with CORT. By submitting information to us through the provided forms, you consent to our placing your email address on this "opt-in" list.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
4. How We Share the Information We Collect
We may share your information with third-party business partners, for instance, for the purpose of enhancing our products and services or so that they can market their products or services to you. If you do not want us to share your personal information with these companies, contact us at PrivacyQA@cort.com and include the CORT domain at issue.
We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us and use measures to protect the confidentiality and security of your personal information.
These services may include:
• Providing our relocation services, fulfilling orders and delivering packages
• Payment processing
• Providing customer service
• Sending marketing communications
• Conducting research and analysis
We may share your geo-location data with third parties for the purpose of them serving you ads for places (such as restaurants) in your area. If you do not wish to allow us to share your information in this manner please opt-out by contacting us at firstname.lastname@example.org and include the CORT domain at issue.
We have the right to disclose and transfer user lists and related personally identifiable information in connection with any merger, sale or contemplated sale of all or part of our business related to the Site and to treat such information as a business asset in the event of bankruptcy or liquidation. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
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. We may also disclose personally identifiable information to a third party if disclosure is required to comply with a subpoena, court order and/or other legal instrument, legal proceeding or relevant law; or if there is an immediate, imminent threat to the safety of any person, CORT or the Site.
We may also disclose your personal information to any other third party with your prior consent.
5. Removal from CORT's "Opt-in" Email List.
Should you wish to stop receiving emails from CORT Business Services, you may remove yourself from the "Opt-in" email list by sending an email to email@example.com and include the CORT domain at issue.
You may also contact us in the following ways:
• Phone: 800.962.CORT (2678)
• Fax: 703.968.8502
15000 Conference Center Drive
Chantilly, VA 20151
We use industry-standard security methods such as firewalls, encryption and system access controls. However, as no computer or network-based product exists that can provide "perfect security," we cannot guarantee that the steps we have taken to secure your information will prevent our systems from being compromised and your information from being disclosed. If you have any questions about the security of your personal information, you can contact us at PrivacyQA@cort.com.
7. Modifying Information.
Upon request CORT Business Services Corporation 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 clicking this link PrivacyQA@cort.com and include the CORT domain at issue. We will respond to your request within a reasonable timeframe.
In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.
8. Links To Other Websites.
The Site may contain links to websites that are not affiliated with CORT and that may or may not have similar practices in place to protect the privacy of information that you supply. We encourage you to review the privacy statements of each of the sites that are linked to or accessed from the Site so that you will be aware of how each visited site collects, uses and distributes such information. We are not responsible for the privacy practices employed by third-party sites.
9. Contact Us.
CORT Business Services Corporation
15000 Conference Center Drive
Chantilly, VA 20151
Phone: 800.962.CORT (2678)
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 [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
CORT Business Services Corporation has further committed to cooperate with the EU data protection authorities (DPAs) for EU employees, and the Swiss Federal Data Protection and Information Commissioner for Swiss employees, with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU or Switzerland, respectively, in the context of the employment relationship.
Websites owned and operated by CORT Business Services Corporation: