Wilke Global is committed to maintaining the highest standards of confidentiality and security for all data collected by our clients and housed on our computer systems.
Privacy Standards and Practices
Wilke Global complies with EU Privacy Shield Framework, as set forth by the US Department of Commerce and European Commission, which provides a compliance mechanism with EU data protection requirements regarding collection, use, transfer, and retention of personal data from the European Union to the United States. Wilke Global certifies that it adheres to EU Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and liability / enforcement. Visit https://www.privacyshield.gov/ to learn more about EU Privacy Shield program
Personal Data Collection – Mechanism & Purpose
Wilke Global provides web applications and data hosting services to its clients. Data is collected in two ways.
- Our clients collect (usually via phone calls initiated by their customers) and maintain general and sensitive data (name, address, phone numbers, email addresses, descriptions of experiences with the company and its products, etc.) on their customers who have explicitly contacted them.
- Wilke Global may collect data on behalf of its clients via automated mechanisms (such as emails, web forms, RSS feeds and APIs) in order to enable clients to research, respond, to and report on their consumers issues.
All data collected is owned by our clients and resides on Wilke Global’s servers in Columbus, OH, USA. Our clients maintain their own privacy policies regarding the consumer data they collect.
Personal Data Collection – Notification to EU Individuals
Since data is collected by and for our clients from consumers and individuals who have explicitly contacted them, it is our clients’ responsibility to properly inform individuals, whose personal data they have collected and entered into our system, of their rights under EU Privacy Shield to access, correct, or delete their personal data. Our clients maintain their own privacy policies and adherence to EU Privacy Shield.
Personal Data Collection – Use & Aggregation
Wilke Global does not use, sell, or otherwise disseminate personal data that is collected by its clients. Data is merely housed and maintained on our servers for our clients’ (data owner’s) use.
Wilke Global periodically aggregates information (e.g., count the number of contact records) for billing purposes only. The aggregated information does not include personal data that can be used to identify persons or organizations.
Personal Data Collection – Retention, Deletion, Defaults
Retention of data (the period of time the data is kept until either deleted, masked, or otherwise cleansed in such a way to remove the identity of persons and organizations) is controlled and executed by our clients based on their organizational policies and their regulatory requirements.
When our clients delete consumer data, all copies of that data (including on-site backups and off-site / DR copies) are permanently removed within a few weeks.
When a client stops using Wilke Global systems and services, all data is securely transferred to that client and promptly deleted from our environment and backup copies.
In the case of a Wilke Global client default (if a client is no longer a business entity), Wilke Global will make a reasonable effort to identify its holding or parent company in order to securely transfer the data to them. If unsuccessful in locating a parent company, Wilke Global will destroy all data belonging to that defaulted client.
Personal Data Collection – Security
Wilke Global uses industry standard security measures to protect the data housed on our systems, including the use of encryption, firewalls, and virus detection. Wilke Global’s servers are hosted in secure locations with 24×7 security and physical access controls. Only authorized employees have physical or electronic access to the hosted systems. We comply with “Open Web Application Security Project” (OWASP) security requirements and framework.
Website and Web Application usage Data
Our website and web applications capture incoming IP addresses, which is a common practice among web service providers including search engines such as Google & Yahoo. It enables us to prevent misuse and overuse from any individual computer or entity. The IP address is recorded in its raw numeric form and is not associated with name, mailing address or other identifiable consumer information. We do not collect, report, distribute, or sell this information for any marketing, tracking, or sales-related purpose.
Personal data is never shared by Wilke Global with any third parties unless specifically requested by our clients. In most cases, sharing of data is executed directly by our clients with no involvement by Wilke Global.
Disclosures required by law
In certain circumstances, it is possible that personal information may be subject to disclosure pursuant to judicial subpoena, warrants, and orders as well as other lawful requests by public authorities and law enforcement, including national security requirements.
Based on ownership of data, this should be executed by our clients, but Wilke Global will do so if so ordered.
Recourse, Enforcement, Liability
Wilke Global Inc.
ATTN: Privacy Manager
545 Metro Place South Ste 200
Dublin, OH 43017
Wilke Global has further committed to refer unresolved privacy complaints under EU Privacy Shield Framework to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD PROGRAM, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Wilke Global, please visit the BBB EU PRIVACY SHIELD PROGRAM web site at http://www.bbb.org/EU-privacy-shield/ for more information and to file a complaint.
The enforcement authority with jurisdiction over Wilke Global’s compliance with EU Privacy Shield is the Federal Trade Commission. Under certain limited conditions, EU individuals may be able to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.