Privacy Policy
PRIVACY POLICY
Morrell® Targets (“us”, “we”, “our”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of morrelltargets.com (“site”). This Privacy Policy applies only to information that you provide to us through this site. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the site. You are advised to consult this policy regularly for any changes.
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to, collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our company within the United States or internationally.
We are committed to protecting your privacy. Authorized employees within the company on a need to know basis only use any information collected from individual customers. We constantly review our systems and data to ensure the best possible service to our customers. We will investigate any such actions with a view to prosecuting and/or taking civil proceedings to recover damages against those responsible.
We do not sell, trade, or otherwise, transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. If you would like to opt out from information other than what is required by law, please contact us at the information listed on our Contact page.
MORRELL MANUFACTURING, INC. GDPR POLICY
Introduction
The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Our Commitment
Morrell Manufacturing, Inc. (‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognize our obligations in updating and expanding this program to meet the demands of the GDPR.
Morrell Manufacturing, Inc. is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Preparing for the GDPR
Morrell Manufacturing, Inc. already has a consistent level of data protection and security across our organization. However, we aim to be fully compliant with the GDPR by May 25, 2018
Our preparation includes: -
- Information Audit - carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
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Policies & Procedures - revising/implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -
- Data Protection – our main policy and procedure document for data protection have been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
- Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – where Morrell Manufacturing, Inc. stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
- Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Privacy Notice/Policy – we are revising our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent - we are revising our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
- Direct Marketing - we are revising the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large-scale processing or includes a special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements – where we use any third-party to process personal information on our behalf (e., Payroll, Recruitment, Hosting, etc.), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place and compliance with the GDPR.
- Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via in the office of an individual’s right to access any personal information that Morrell Manufacturing, Inc. processes about them and to request information about: -
- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
- The right to request erasure of personal data (where applicable) or to restrict processing by data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organisational Measures
Morrell Manufacturing, Inc. takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including an SSL, access controls, password policy, encryptions, practices, restriction, IT, and authentication.
GDPR Roles and Employees
Morrell Manufacturing, Inc. has designated Shanna Bourne as our Data Protection Officer to develop and implement our roadmap for complying with the new data protection Regulation. Responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures, and measures.
Morrell Manufacturing, Inc. understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees before May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please email info@morrelltargets.com.
SMS/MMS MOBILE MESSAGING MARKETING PROGRAM
We respect your privacy. We will only use information you provide through the
Program to transmit your mobile messages and respond to you, if necessary.
This includes, but is not limited to, sharing information with platform providers,
phone companies, and other vendors who assist us in the delivery of mobile
messages. WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR
OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR
CUSTOMER INFORMATION COLLECTED THROUGH THE PROGRAM TO
ANY THIRD PARTY. Nonetheless, We reserve the right at all times to disclose
any information as necessary to satisfy any law, regulation or governmental
request, to avoid liability, or to protect Our rights or property. When you complete
forms online or otherwise provide Us information in connection with the Program,
you agree to provide accurate, complete, and true information. You agree not to
use a false or misleading name or a name that you are not authorized to use. If,
in Our sole discretion, We believe that any such information is untrue, inaccurate,
or incomplete, or you have opted into the Program for an ulterior purpose, We
may refuse you access to the Program and pursue any appropriate legal
remedies.
California Civil Code Section 1798.83 permits Users of the Program that are
California residents to request certain information regarding our disclosure of the
information you provide through the Program to third parties for their direct
marketing purposes. To make such a request, please contact us at the following
address:
Morrell Manufacturing, Inc.
1721 Hwy 71. N.
Alma, AR 72921
info@shopmorrelltargets.com
This Privacy Policy is strictly limited to the Program and has no effect on any
other privacy policy(ies) that may govern the relationship between you and Us in
other contexts.