Overview

In the course of conducting mailing and information services on behalf of our clients, Walz Secured Outsourcing collects and processes personally identifiable information of our clients’ customers, shareholders, employees, suppliers, business partners, Web site visitors and other persons (Personal Data).   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 financial data useful in identity theft, or other similar data (“Sensitive Personal Data”).

This policy applies to Walz Secured Outsourcing, LLC (“Walz”), and is effective as of March 15, 2004.  All Walz employees and agents working on Walz’ behalf will be required to abide by this policy.

This policy is designed to protect Personal Data under applicable law as it is currently exists, specifically Title V of the Gramm-Leach-Bliley Act of 1999.  However, Walz realizes that this policy cannot address every potential issue and circumstance.  Therefore, we acknowledge that this policy is subject in all respects to applicable local legal and regulatory requirements and existing agreements and confirm that we will comply with such requirements and existing agreements.

Privacy Principles

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

Choice/Fair Processing

We will process Personal Data only with consent of our clients 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 affected individuals 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 never allow Personal Data to be disclosed to a third party for direct marketing purposes under any circumstances.

Access

Personal Data will be accessible and processed only by (i) Walz employees, suppliers, business partners and others who require access for the performance of their obligations to Walz; (ii) any person granted access by the client from whom Walz obtained the Personal Data; or (iii) those otherwise authorized by law or court order.

Access to Personal Data means any access, even glimpses of names or addresses on mailing labels and the names or addresses of the clients for whom Walz is performing the services.

Security/Integrity

We will take reasonable security procedures through appropriate physical, 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 our clients to provide all relevant information and to advise us of any changes to the Personal Data in their files to ensure that it remains accurate, complete and current.

Onward Transfer

When we transfer Personal Data within Walz or to third parties (including our suppliers and business partners), we will observe the privacy principles of Choice and Security/Integrity (described above), and we expect 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.

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
   

Walz Web Sites

In addition to all other Personal Data handled by Walz, this policy applies to Personal Data collected through Walz web

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 Walz, and as such, we are not responsible for their content.

Updating the Policy

Changes in legislation and/or our business activities may require that this policy be updated from time to time.

Contact Us

If you have any questions or comments about this policy or our privacy practices, please contact us.

•   Phone: 909 491-6800; Fax: 909 491-6599
•   Street Address:
        Chief Privacy Officer
        Walz Secured Outsourcing
        43234 Business Park Drive Ste 107
         Temecula, CA  92592-3604