PRIVACY POLICY

This Privacy Notice addresses how Walpole, Inc. ( “Walpole”), may collect and process personal information from you. Walpole interacts with individuals in a variety of ways, such as customers of our services and employment applicants, and others in our communities. To enable these interactions, Walpole may need to collect and process personal information. Walpole has implemented technical, administrative, and measures to safeguard any personal information we may collect. As this Notice is intended to cover a variety of situations, some information in this Notice may not apply to you. Also, Walpole complies with applicable legal requirements and refrains from the collection or use of personal information in a location as prohibited by applicable law. Walpole defines personal information as any data that relates to an identified or identifiable person.

Personal information Walpole might collect

The personal information that Walpole collects is subject to applicable legal requirements. Because this Notice covers a wide variety of situations, there may be data elements listed here that do not apply to your specific situation. Types of information collected may include your name, basic identification information, contact information, work information, and other information depending on the reason for your interaction with our website.
In countries or states that impose special protections on sensitive or special personal information (as defined by applicable law), Walpole will only collect, process, or transfer your sensitive personal information as required by law or, in circumstances where providing the data is optional, with your consent. Walpole will generally collect the personal information from you when you provide it to us, use Walpole applications, networks, systems and services, and via third parties (such as employment applications). Our collection of your personal information will be consistent with applicable law.

Walpole’s use of the personal information it collects

How your personal information is used depends on the purpose for which you are interacting with our website. For customers seeking our services, your information may be used to provide you with information on requested products and services. For individuals seeking employment, your information will be provided to a third party service to evaluate your application for employment.

Walpole may share the information it collects

Walpole may provide access to or share your personal information on an as-needed basis with third parties, such as trusted service providers, consultants and contractors who are granted access to Walpole systems. Please note that in some instances, our website automatically transfers you to a third party provider’s website wherein you will be providing your personal information directly to the third party. Walpole will only share your personal information outside Walpole to service providers Walpole has retained to perform services on our behalf. The categories of service providers with which Walpole may share your personal information include contractors, screening provider, outsourced digital technology providers, and service providers offering software as a service. Walpole will only share your personal information with service providers whom Walpole has contractually restricted from using or disclosing your personal information except as necessary to perform services on our behalf or to comply with legal requirements and responding to a court proceeding or a legitimate legal request from law enforcement authorities or other government regulators. If you provide services to Walpole, Walpole may need to provide your personal information to that customer or end user. Except where used in support of a contract with you or to fulfill a legal obligation, our use of your personal information will be only for legitimate business interests as set forth above. Walpole will not sell your personal information.

Where Walpole stores your personal information

Walpole stores your personal information in its database. On certain occasions, we may transfer your personal information consistent with applicable legal requirements and only to the extent necessary for the purposes set forth above. Walpole relies on available legal mechanisms to enable the legal transfer of personal information and that are intended to ensure an adequate level of protection, as required by law.

How long does Walpole retain personal information

Walpole retains personal information for the length of time required to fulfill the purpose for which it was originally collected and for any additional period as required by applicable law or regulation, court, administrative or arbitration proceedings, or audit requirements.


Your choice on how Walpole uses your personal information

It will be your decision whether or not to provide your personal information. However, there may be circumstances in which you will not be provided with a choice, such as IT security practices like virus and malware scanning for individuals with access to Walpole networks. Depending on the nature of the personal information and the reason that Walpole may require it, Walpole may be unable to fulfill your request without collecting and processing your personal information. You will always have a choice about whether Walpole uses your personal information for marketing purposes. If you have provided us with your personal information and would now like to request that it is no longer used for marketing purposes, please contact us. We also encourage you to use the unsubscribe option available in the communication.

Additional information

Residents of the United States: Walpole does not collect Social Security Numbers through our website. Walpole does, however, collect Social Security Numbers where required by law, such as tax and payroll purposes for its employees. When Walpole collects and/or uses Social Security Numbers, Walpole will take proper care by protecting confidentiality, limiting collection, ensuring access on a need-to-know basis, implementing appropriate technical safeguards and ensuring proper disposal.

Walpole may change this policy

From time to time, Walpole may update this policy. By continuing to interact with us after the modified version of the policy has been posted, you are accepting the changes to the policy, subject to any additional requirements that may apply. We encourage you to review this policy on a regular basis for any changes.

privacy policy