Privacy Policy

Our Commitment to Privacy

As a global company which conducts business in the electronic marketplace, we believe that it is our responsibility to set industry‐leading standards in our approach to the protection of Personal Information. Not only do we strive to collect, use and disclose Personal Information in a manner consistent with the laws of the countries in which we do business, but we also aim to uphold the highest ethical standards in our business practices.

As part of our commitment to privacy, MidPointe Library complies with the EU General Protection Regulation (‘GDPR’) in respect of any personal data we process on behalf of our clients who are subject to the GDPR as data controllers. See our GDPR policy below for details.

Definitions of Terms Used

“Personal Information” means information that is transferred from the EU, UK, or to the U.S.; is recorded in any form; and pertains to a specific individual or can be used to identify an individual, either directly or indirectly.

“Sensitive Personal Information” means Personal Information specifying medical or health conditions, racial or ethnic origin, political opinions or philosophical beliefs, trade union memberships or information concerning the sex life of the individual.

“Agent” means any third party that uses Personal Information provided by MidPointe Library to perform tasks on behalf of or at the instruction of MidPointe Library and who is bound by a Confidentiality Agreement.

“Processing” of Personal Information means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

Notice, Choice & Accountability for Onward Transfer

MidPointe Library does not collect Personal Information about individuals through its websites except when such individuals specifically provide such information on a voluntary basis such as through our subscription registration for news or blog updates, a request for samples or Whitepapers, employment submissions via the website or via an email sent to us through our website.

MidPointe Library uses cookies on its websites. A “Cookie” is a small text file created by a website you visit that is stored on your computer either temporarily or permanently. Cookies do not store Personal Information about you, unless you knowingly provide it. Cookies provide a way for the website to recognize you and keep track of your preferences. For example, cookies allow our websites to recognize your browser as a previous visitor, and thus save and remember any preferences that may have been set while you were previously browsing our websites. You have control over the use of cookies. Most Web browsers are set to accept cookies by default. If you prefer, you can choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect your Internet experience, disabling certain functions. You can also erase cookies that are already on your computer. Currently, various browsers offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to websites visited by the user about the user’s browser DNT preference setting. At this time, MidPointe Library does not respond to DNT signals, whether that signal is received on a computer or on a mobile device. It should be noted that if you click on a link to a third party website or service provided on our website, a third party may transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

MidPointe Library is committed to safeguarding our client confidences, including any Personal Information received from or about our clients or from or about their third party business associates. MidPointe Library will not share Personal Information with third parties for purposes other than those in support of MidPointe Library’s business operations and as necessary to facilitate the purpose for which it was provided. MidPointe Library personnel, third party agents and third party administrators are required to treat this information confidentially and to use and disclose it only to provide the services for which MidPointe Library was retained. Accordingly, MidPointe Library has in place written agreements with client organizations using our services, as well as our third party agents and administrators which require, amongst other things, that parties safeguard Personal Information, and abide by all applicable laws. For our clients who are subject to the GDPR, the agreements will set forth a permissible basis for the onward transfer of Personal Information from the EU, EEA, UK, or to the United States. Except as set forth in this privacy statement, MidPointe Library does not disclose Personal Information received from its clients to third parties without its clients’ consent. To the extent permitted by Privacy Shield, the FCRA and other applicable laws, MidPointe Library reserves the right to process Personal Information in the course of our internal business operation without the knowledge of the individuals involved.

MidPointe Library does not provide Personal Information to third parties for their marketing purposes.

MidPointe Library will offer individuals the opportunity to choose (opt out) whether their Personal Information is (a) to be disclosed to a non-Agent or non-third party administrator or (c) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, we will give individuals the opportunity to affirmatively and explicitly (opt in) consent to the disclosure of the information to a non-Agent third party or non-third party administrator or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

In the event you decide that you want to opt out from MidPointe Library’s use of your Personal Information that you previously provided to MidPointe Library, notify us by email at: chillman@midpointelibrary.org

We may also use or disclose your Personal Information, if necessary, to protect and defend the rights or interest of MidPointe Library or others.

MidPointe Library may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company, transfer, sell or assign your Personal Information to third parties involved in the aforementioned events.

Security, Data Integrity and Purpose Limitation

MidPointe Library combines technical and physical safeguards with employee policies and procedures to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction. MidPointe Library employs Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our Website. We have installed layered firewalls and other security technologies to help prevent unauthorized access to our systems. The servers used to store Personal Information are maintained in a secure environment with appropriate security measures. Password protection protocols are utilized on all computers.

Furthermore, only employees and agents who need the information to perform a specific job are granted access to Personal Information and all employees and agents undergo a thorough background screening and/or vetting process and are trained to ensure that information is handled responsibly and in accordance to this Privacy Policy.

MidPointe Library will use your Personal Information only in a manner that is compatible with the purpose for which it was collected or authorized by the individual or our client. MidPointe Library will take commercially reasonable measures to ensure that Personal Information is accurate, complete, current, and otherwise reliable with regard to its intended use. Data will be retained only for as long as it serves its relevant purpose and in consideration of correlated compliance and legal considerations.

International Data Transfers

We are headquartered in the United States and we will process your personal information in the United States. Your personal information will be transferred to and stored in the United States. When we transfer personal information from the European Union (EU), the United Kingdom, or the European Economic Area (EEA) to the United States, we will implement appropriate and suitable safeguards to ensure that such data will be protected as required by applicable data protection law. Our Privacy Shield certification confirms this.

Privacy Shield Policy

MidPointe Library (“MidPointe Library,” “we,” “us,” “our”) complies with the EU-U.S. Privacy Shield Framework and the U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and to the United States, respectively. MidPointe Library has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

The “Notice, Choice & Accountability for Onward Transfer” section of this Privacy Shield Policy will also apply to California residents who visit our website (See CalOPPA Section below).

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, MidPointe Library is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Access

MidPointe Library acknowledges that EU and UK individuals have the right to access the personal information that we maintain about them. Upon request, and with proof of identity, we will grant individuals reasonable access to their Personal Information that MidPointe Library holds about them in response to a lawful request by public authorities having jurisdiction over MidPointe Library. Pursuant to the Privacy Shield Frameworks, EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to chillman@midpointelibrary.org. If requested to remove data, we will respond within a reasonable timeframe.

Although we make every effort to ensure that the data we collect and store about you is as accurate as possible, we cannot guarantee that third parties are accurate in information that they transmit and therefore we are not responsible for the accuracy of the data that may be supplied by any third-party sources of information or our clients.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to chillman@midpointelibrary.org.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

MidPointe Library’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, MidPointe Library remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless MidPointe Library proves that it is not responsible for the event giving rise to the damage.

Recourse, Enforcement and Liability

In compliance with the Privacy Shield Principles, MidPointe Library commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and UK individuals with Privacy Shield inquiries or complaints should first contact MidPointe Library by email at chillman@midpointelibrary.org.

Dispute Resolution for EU Individuals

MidPointe Library has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

EU General Data Protection Regulation – GDPR Privacy Policy

This section only applies if we collect Personal Information from you pursuant to our contract with a client who is subject to the GDPR and if you are an individual residing in the European Union or European Economic Area or we collect the Personal Information from you while you are in the EU.

For purposes of the GDPR, our client will act as data “controller” and we will act as the data “processor” under the GDPR. Some of the provisions set forth in this GDPR Privacy Policy (namely, Categories of Personal Information Collected; Sharing your personal information; and Access) will also apply to California resident consumers who visit our website (See CalOPPA Section below).

As a global company which conducts business in the electronic marketplace, we believe it is our responsibility to set industry-leading standards in our approach to the protection of your personal data. Not only do we strive to collect, use and disclose information in a manner consistent with the laws of the countries in which we do business, but we also aim to uphold the highest ethical standards in all our business practices.

In the context of both MidPointe Library and our clients complying with GDPR in relation to personal data relating to people in the EU / EEA, this section explains:

What information we collect and why
How we use the information
What choices you have with respect to the information

What information do we collect?

“Personal information” is any information that can be used to identify you or that we can link to you.

We may collect and process personal information about you in the course of our business:

through your use of our website;
if you apply for employment or become employed by us;
if you are a supplier/partner;
if you are a client; or
as a result of your relationship with one or more of our staff or clients.

The following categories of personal information may be collected and processed:

Contact information: your name, position, role, company or organization, telephone, email and postal address;
Business information: data identifying you in relation to matters on which you instruct us or in which you are involved;
Supplier/partner data: contact details and other information about you or your company or organization where you provide products or services to MidPointe Library;
Social media: posts, Likes, tweets and other interactions with our social media presence;
Technical information: when you visit our website and other platforms – information collected through cookies and other tracking technologies such as IP address, URL, browser type and version, time zone setting, traffic data, location data, browser plug-in types and versions, operating system you are using, device type, hardware model, unique identifiers and mobile network information, web logs, and the resources that you access;
Information from public sources: such as LinkedIn and other professional networks, online directories, internet publications, etc.;
Identity data: first name, maiden name, last name, username, marital status, title, date of birth, ID number, photograph, gender, etc.
In relation to candidates and employees: CV/resume, certifications, licenses, references, education, criminal record, driver record, employment history
Criminal record data: where permitted by national law and appropriate to do so.

The legal basis for processing your personal information MidPointe Library may process your information because:

Processing is necessary for the performance of a contract with you or to take steps to enter into a contract
You have given explicit permission (consent) to do so
Processing is necessary for compliance with a legal or regulatory obligation
Processing is necessary in order to protect your vital interests or those of another person
Processing is necessary for our legitimate interest or a third party’s legitimate interest in carrying out business

The following are examples of how we may use your personal information:

Managing our business and relationship with you or your company or organization;
Understanding and responding to inquiries and client feedback;
Understanding how our clients use our services and websites;
Improving our services and offerings;
Ensuring our systems and premises are secure;
Managing our supply chain;
Direct marketing; and
Fraud prevention

Where does the information we collect come from?

Personal information may be provided to us by you, your employer, a company or organization who is our client or our suppliers.

Information may come from:

Information you provide to us – such as contact details that you provide when you request sample reports or request other services or when you respond to our communications or apply for a job
Information we may collect automatically – such as browser cookies and similar technologies
Information we collect from other sources

Your rights about your personal information

Under certain circumstances, and subject to local law, you may have the following rights under data protection laws with relation to the personal data we and our clients hold about you:

In summary, those include the:

Right to be informed – you have the right to be informed about the collection and use of your personal data.
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to erasure – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
Right to restrict processing – where certain conditions apply, you have the right to restrict the processing.
Right to data portability – you have the right to have the data we hold about you transferred to another organization.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to withdraw consent – if we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Right to complain – if you are not satisfied with our use of your personal information or our response to any request by you to exercise your data protection rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the authority that supervises our processing of your personal information.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

Sharing your personal information

MidPointe Library will not share any personal information with third parties unless required by law, required to enable the fulfilment of the purpose for which the personal information was originally supplied or as otherwise set out in this policy. We may share certain types of personal data with our affiliated companies (such as Visual Compliance,RDC for adverse media lookups, payment processing, targeted advertising and analytics), but only for the purposes set out in this privacy policy and we remain responsible for the management and security of your personal information. Lastly, we may permit select third parties to access your personal information for the purposes outlined in this privacy policy. MidPointe Library remains liable to you in respect of our obligations concerning your personal data in cases of onward transfers to third parties. Any transfer of your personal information will be compliant with applicable data protection law.

In submitting personal information to our website, the user is giving explicit consent for such usage. In the circumstances of a merger or sale of part or all of our business, personal information held by us will be one of the transferred assets.

Protection and storage of the information we collect

We use a combination of administrative, technical, personnel and physical measures designed to comply with applicable legal requirements to safeguard the Personal Data in our possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Although we will do our best to protect your personal information, we cannot guarantee the absolute security of your personal information and any transmission is at your own risk. Once we receive your personal information, we use strict procedures and security features to try to prevent unauthorized access. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

Processor Obligations

The GDPR places certain obligations on Processors of Personal Data. As a Processor of Personal Data, MidPointe Library will:

Only process Personal Information to the extent and for the purpose authorized by our client (the “Controller”)
Inform Controller, without undue delay, if any instruction provided by Controller may infringe upon GDPR law
Implement appropriate technical and organizational measures to protect the security of data
Inform the Controller without undue delay upon learning of a breach
Ensure all individuals authorized to process the data have committed to confidentiality agreements
Assist Controller in handling data subject access rights requests
Assist Controller with obligations around security and requests from supervisory authorities
Be available and able to assist Controller with compliance obligations
Delete or return all data upon Controller request or requirement
Outline any data transfers outside EEA and describe safeguards which will protect the data
Assist Controller with audits
Ensure any engagement of sub-processors meet same obligations required by the Controller
Only engage sub-processors upon approval of Controller

How can you contact us?

MidPointe Library (MidPointe Library) is registered in the state of Ohio, USA under Charter Number 801410

If you have any questions about this Privacy Policy or regarding any other privacy matters, please contact us at:

MidPointe Library
3825 Edwards Rd
Cincinnati, Ohio 45209 USA
Phone: +1 866.987.8880
Email: chillman@midpointelibrary.org

Links to Other Sites

This website may contain links to third party sites which operate independently of MidPointe Library. We provide these links merely as a convenience and the inclusion of such links does not necessarily imply an endorsement or warranty of those links or their associated websites. These sites have established their own privacy and security policies. For the best online experience, we encourage you to review these policies before submitting any Personal Information through these sites.

Children’s Online Privacy Protection Rule (COPPA)

MidPointe Library does not knowingly collect information from children under the age of 13 and does not target its websites to children under 13. Please contact us at privacy@MidPointe Library.com if you believe we have inadvertently collected Personal Information of a child under 13 without proper parental consents so that we may delete such data as soon as possible.

California Consumer Privacy Act of 2018 (CCPA)

We are not subject to the California Consumer Privacy Act of 2018 because we do not meet the definition of “business” under Section 1798.140 of the California Civil Code. In the event we receive Personal Information from a client or third party who is subject to the CCPA, we agree to the following restrictions on our use or disclosure of this Personal Information and we hereby certify that we understand these restrictions and will comply with them. We are prohibited from:

(i) Selling the Personal Information

(ii) Retaining, using, or disclosing the Personal Information for any purpose other than for the specific purpose of performing the services specified in our contract with our client, including retaining, using, or disclosing the personal information for a commercial purpose other than providing the services specified in the contract; and

(iii) Retaining, using, or disclosing the information outside of the direct business relationship between us and our client.

California Online Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach streaches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California resident consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. Learn more about CalOPPA at the Consumer Federation of California’s website. The GDPR and Privacy Shield sections of this Privacy Policy listed below will apply to California resident consumers covered by the CalOPPA.

In compliance with CalOPPA, we certify to the following:

We created a privacy policy and added a link to it on our home page.
Our privacy policy link includes the word “privacy,” and can easily be found on this page.
Users can view any privacy policy changes by re-visiting this web page.
Users are able to change their Personal Information by emailing us.
We do not collect Personal Information about your online activities over time and across third-party websites or online services.
For information about the categories of Personal Information we collect see GDPR Policy: Categories of Personal Information Collected.
For information about the identities of third-party entities with whom we may share your Personal Information see GDPR Policy: Sharing your personal information.
For information about about our response to “do not track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of Personal Information, see Privacy Shield Policy: Notice, Choice & Accountability for Onward Transfer.

Updates to this Privacy Policy

MidPointe Library reserves the right to amend this Privacy Policy at any time without notice. However, if we change how we use your Personal Information, we will post the policy change notification on the website and we will update this Privacy Policy accordingly. We encourage you to periodically review this Privacy Policy for the latest information on our privacy and security policies.

Contact Us

If you have any concerns regarding the collection and use of your Personal Information or any other privacy matters, please contact us.

The foregoing policy is effective as of March 1, 2020.