Updated April 23, 2015
We at Simpson Manufacturing Company, Inc., (Simpson) respect your concerns about privacy and value the relationship we have with you. In doing so, we strive to maintain our business environment of fairness, high ethical standards, and honesty.
Simpson and its applicable subsidiaries have certified that they comply with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, storage, transfer, use and other processing of consumer and customer personal information from European Union member countries and Switzerland. In addition, the foreign European subsidiaries of Simpson certify that they abide by any local regulations that are not covered by this policy.
Simpson's Safe Harbor certification can be found at https://safeharbor.export.gov/list.aspx. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce's Website at http://export.gov/safeharbor/.
For the purpose of this Policy, "Personal Information" means information that (i) is transferred from European Union member countries and / or Switzerland to the United States, (ii) is recorded in any form, (iii) is about, or relates to, an identified or identifiable consumer (employee, supplier or consultant) or customer, and (iv) can be linked to that consumer or customer. This Policy outlines our general policy and practices for implementing the Safe Harbor privacy principles for online and offline Personal Information.
II. Safe Harbor Privacy Principles
Simpson’s practices regarding the collection, storage, transfer, use and other processing of Personal Information comply with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement oversight.
Simpson notifies, through its website and by other means, our consumers and customers located in the European Economic Area (EEA) and Switzerland about the purpose for which we collect and use Personal Information and how to contact us about our practices concerning Personal Information.
Simpson does not disclose Personal Information to third parties.
Purpose of Collection and Use of Personal Information
Simpson collects certain Personal Information such as:
- For Employees; name, title, department number, home address, telephone numbers, email address, date of hire, date of birth, gender, degrees, and compensation information.
- For Suppliers and Customers: : name, address, bank details, and means of payment.
Simpson may collect some information defined by the Safe Harbor framework as Sensitive Personal Information.
We use Personal and Sensitive Information only for internal administrative and analytic purposes and to comply with our legal obligations, policies and procedures. Due to their unique nature, Simpson has addressed on its website the process and procedures for whistleblower communications.
Simpson may disclose Personal Information (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on an enforceable government request or as may be required under applicable law, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.
We do not use Personal Information for purposes incompatible with the purposes for which the information was originally collected without notifying the relevant consumers of such uses and offering an opportunity to opt out.
Onward Transfer of Personal Information
We may share Personal Information with service providers we have retained to perform services on our behalf. We require service providers to whom we disclose Personal Information and who are not subject to laws based on the European Union Data Protection Directive and / or the Swiss Federal Act on Data Protection (FADP) to either (i) subscribe to the Safe Harbor principles or (ii) contractually agree to provide at least the same level of protection for personal information as is required by the relevant Safe Harbor principles.
Access to Personal Information
Simpson provides consumers and customers with reasonable access to the Personal Information maintained about them. We also provide a reasonable opportunity to correct, amend or delete that information where it is inaccurate. Consumers or customers also have the right to raise for legitimate grounds, an objection to the storage of Personal Information except if the information is stored to comply with legal obligations. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles. To obtain access to Personal Information, consumers and customers may contact Simpson as specified in the "How to Contact Us" section of this Policy.
Security of Personal Information
Simpson maintains reasonable administrative, technical and physical safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Simpson takes reasonable steps to ensure that Personal Information the company collects is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current. We depend on our consumers and customers to update or correct their Personal Information whenever necessary.
Enforcement and Oversight
Simpson has established procedures for periodically verifying implementation of and compliance with the Safe Harbor principles. We conduct an annual self-assessment of our practices with respect to Personal Information to verify that representations we make about our Personal Information privacy practices are true and that related privacy policies have been implemented as represented.
Employees will be properly trained to adhere to these principles. Any employee who has been determined to be in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Simpson management has designated the Global Compliance Manager to be responsible for the administration, interpretation, and application of this policy, and to handle all questions or other clarifications of this policy and its related responsibilities. Management has designated the Director of Internal Audit to be responsible for the monitoring and periodic reviews regarding compliance and annual self-assessment requirements. Consumers and customers may file a complaint with Global Compliance Manager in connection with Simpson's processing of their Personal Information under the Safe Harbor principles. Simpson will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy. Simpson is subject to the laws and regulation of the Federal Trade Commission and will take steps to remedy any problems arising out of a failure to comply with the Safe Harbor principles.
Additionally, Simpson management has elected to use the EU Data Protection Authorities (DPAs) as the Independent Recourse Mechanism (IRM) to investigate unresolved complaints concerning the data covered by this policy. Simpson management has agreed to cooperate with the DPAs in the investigation and resolution of complaints brought under Safe Harbor.
For more information about DPAs or to find a country specific Data Protection Authority please visit the European Commission’s Data Protection website:
Home Page: http://ec.europa.eu/justice/data-protection/index_en.htm
National Data Protection Authorities: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
III. How to Contact Us
Simpson Manufacturing Company Inc.
Attention: Global Compliance Manager
5956 West Las Positas Blvd
Pleasanton, CA 94588