This privacy statement applies to the online services (the “Services”) branded under the Aspen iFamily™ suite of services, all other property solution services and other online services provided by Aspen Grove Solutions. The Services provided are owned by Aspen Grove Solutions (hereafter Aspen) a Delaware corporation and any of its successors, assigns and affiliates (“Aspen”).

Aspen is committed to protecting your privacy. This “Privacy Statement” explains data collection and use practices of the Aspen sites (the “Site”). By accessing the Site or using the Services, you are consenting to the information collection and use practices described in this Privacy statement.

The Services’ features and capabilities may vary depending on the particular Service(s) to which you subscribe. The terms “you”, “your”, “yourself” and “user” all refer to the person or entity using the Services in any way.

Aspen is a property management solution company with operations in various countries around the world and provides property management solutions to its corporate clients. Aspen processes the personal data belonging to its corporate clients on behalf of those clients. In order to fulfill this function Aspen receives the personal data of individuals from its corporate clients.

STORING OF PERSONAL INFORMATION

Aspen stores and processes personal information on behalf of our corporate clients. Our corporate clients are the data controllers for this data and are responsible for ensuring that it is collected and processed in accordance with their own privacy policy and any applicable laws and regulations. Aspen act as data processors for our corporate clients and are obliged to ensure we meet, or exceed, the data protection and privacy requirements of our corporate clients. In the course of serving its customers, Aspen acquires, stores and transmits customer information that may contain personal information. Personal information – such as the customer’s name, address, telephone number, electronic mail address, skills and qualifications, photographic, insurance policy details, and credit card data – is provided to Aspen by its customers in order to establish and provision service.

Some of our websites enable visitors to provide personal information for the purpose of submitting requests for information or other queries. Such information may include the IP address of your computer, your name, your email address, location and/or phone number. By providing Aspen with this information, you consent to your information being collected, used, disclosed and stored by us in accordance with this Privacy Statement. Any such information is not provided to third parties and will be used by Aspen solely for the purpose you gave it to us. Please note that such personal data may be anonymised to enable Aspen perform statistical, troubleshooting or performance monitoring.

USE OF YOUR PERSONAL INFORMATION

Personal information stored and processed by Aspen will only be used for the purposes it was given to us, whether directly by you or by our corporate clients.

DISCLOSURE OF PERSONAL INFORMATION AND TRANSFERS

Aspen does not disclose an individual’s personal information to third parties except when:

  • Aspen has the individual’s verified permission to make the disclosure;
  • the disclosure is required by law or mandatory professional standards;
  • In response to a valid court order or a search warrant;
  • the disclosure is reasonably related to the sale or other disposition of all or part of Aspen’s business;
  • the disclosure is reasonably necessary for the establishment of legal claims;
  • the disclosure is to another division of Aspen, to an affiliate of Aspen, or to persons or entities providing services on Aspen’s or the individual’s behalf (each a “permitted transferee”), consistent with the purpose for which the information was obtained, if the permitted transferee, with respect to the information in question (a) is subject to law providing at least the same level of privacy protection as required by Aspen; (b) has agreed in writing to provide at least the same level of privacy protection as required by Aspen; or (c) subscribes to the EU Privacy Shield framework as set forth by the US Department of Commerce or equivalent.
  • Permitted transfers of information include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America.

SECURITY

Aspen protects the confidentiality of its customers’ personal contact and account information. To secure the information collected online, prevent unauthorized access, maintain data accuracy and ensure only appropriate use of information that is collected from customers, Aspen has implemented appropriate physical, electronic, and managerial procedures in line with the ISO 27001:2005 Information Security standard. Further, Aspen requires that employees keep customer information confidential.

Aspen cautions its customers and website visitors that no medium of communication, including the Internet, is entirely secure.

DATA INTEGRITY

Aspen processes personal information only in ways compatible with the purpose for which it was collected or authorized. To the extent necessary for such purposes, Aspen takes reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.

DATA ACCESS REQUESTS

There are two ways that Aspen shall respond to individuals’ requests for copies of their personal data held on Aspen’s systems.  These are;

  • Via our corporate clients who are the Data Controller for the personal data in question and who require Aspen to provide that data to them.
  • Should an individual submit their personal data directly to Aspen, for example via a web form on one of our websites, we will supply copies of such personal data. If you wish to obtain such copies, you can contact us via our contact page. In order to process your request in a timely manner you should provide any personal identifiers that you submitted to us such as name, email address or phone number. Your request will be dealt with as soon as possible and will take not more than 40 days to process. Aspen retain the right to charge a small fee, in accordance with the Irish Data Protection Acts 1988, 2003, for these requests if it so wishes.

INACCURATE PERSONAL DATA

If Aspen is holding inaccurate personal data relating to you then you can request us to correct that information.

  • If your data was submitted to Aspen via one of our corporate clients you must submit your request to correct the data via that corporate client.
  • If your data was submitted directly to Aspen that request can be sent directly to us either in writing or via e-mail.

DATA RETENTION

It is Aspen’s policy to retain personal data for no longer than necessary.  For personal data we process on behalf of our corporate clients Aspen will comply with our clients’ data retention policies.

For personal data submitted directly to us, Aspen will only retain that data for as long as it is necessary to carry out the purpose for which that personal data was gathered. Once that purpose is complete the personal data will no longer be retained.

All personal data that is no longer required to be retained shall be securely destroyed.

EU – U.S. Privacy Shield Framework

Aspen complies with the EU-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 to the United States.  Aspen 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/

In compliance with the Privacy Shield Principles, Aspen commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Private Shield policy should first contact Aspen at:

privacy@aspengrovesolutions.com.

Aspen has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints.  If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint.  The services of EU DPAs are provided at no cost to you.

IRISH DATA PROTECTION NOTIFICATION

Aspen has a registered office in Ireland and as such any personal information stored and processed by Aspen will be treated with the highest standards of security and confidentiality and strictly in accordance with the Data Protection Acts, 1988 & 2003.

ENFORCEMENT

Aspen is committed to ensuring all customer personal information is handled in a manner consistent with the purpose for which the information was obtained. If a customer has inquiries or complaints about how their personal information is handled, please send an email to privacy@aspengrovesolutions.com. We will provide answers or begin investigations as necessary.

AMENDMENT

Aspen may amend this policy from time to time by posting a revised policy on this website, or a similar website that replaces this website. If Aspen amends the policy, the new policy will apply to personal information previously collected only insofar as the rights of the individuals affected are not reduced. So long as Aspen adheres to the EU-U.S Privacy Shield Framework, we will not amend our policy in a manner inconsistent with the Privacy Shield Principles.

CONTACT INFORMATION

If a customer has inquiries or complaints about how their personal information is handled, please send an email to privacy@aspengrovesolutions.com. We will provide answers or begin investigations as necessary.

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