Data Privacy Framework Policy

EU-U.S. Data Privacy Framework Policy

This EU-U.S. Data Privacy Framework Policy (“Policy”) describes how McDonough Corporation and its subsidiaries and affiliates in the United States (“US”) (“Company,” “we,” or “us”) collect, use and disclose certain personally identifiable information that we receive in the US from the European Union member countries (“Personal Data”).  This Policy applies to the following US affiliated entities (which are included in the reference to “Company,” “we,” or “us”):  Marmac, LLC; McDonough Construction Rentals, Inc.; Colonial Millworks, Ltd.; and Titan Stairs & Trim, Inc.  This Policy supplements our Website Privacy Policy located at https://www.mcdonoughcorp.com/privacy-policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.  We have certified with the Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (“DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  If there is any conflict between the terms of this Policy and the DPF Principles, the Principles shall govern.  To learn more about the program, and to view our certification, visit https://www.dataprivacyframework.gov/.

We are subject to the investigative and enforcement authority of the Federal Trade Commission (“FTC”).  

Personal Data Collection and Use

We may receive the following categories of Personal Data in the US:  name, address, email address, telephone number and other identifiers by which users of our website may be contacted online or offline.  We process Personal Data for the following purposes:  to present our website and its contents to users; to provide corporate customers, business partners and suppliers with information, products and services that they request from us; to notify website users about changes to our website and our products and services; to allow website users to participate in interactive features of our website; and for any other purpose for which our website users, corporate customers, business partners and suppliers provide consent.  McDonough Corporation will only process Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes the individual later authorizes.  Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out.  McDonough Corporation maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete and current.

Data Transfers to Third Parties

Third-Party Agents or Service Providers.  We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf, including:  to our affiliates; to our contractors and service providers we use to support our business functions; to a buyer or other successor in the event of a merger, restructuring, reorganization or sale of our assets; to fulfill the purpose for which the Personal Data was provided; for other purposes disclosed by us when the Personal Data was provided; and with consent.  We take reasonable and appropriate steps to stop and remediate any unauthorized processing.  Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Disclosures for National Security or Law Enforcement.  Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

McDonough Corporation maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction.

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend or delete it.  These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access.  If you would like to request access to, correction, amendment or deletion of your Personal Data, you can submit a written request to the contact information provided below.  We may request specific information from you to confirm your identity.  In some circumstances we may charge a reasonable fee for access to your information.

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your Personal Data to us at 21050 North Pima Road, Suite 100, Scottsdale, AZ 85255, attention:  Brian O’Brien, Chief Financial Officer.  You may also contact us via email at:  bobrien@marmac.net.  We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint.  For any unresolved complaints, we have agreed to cooperate with JAMS as our independent third party dispute resolution provider.  If you are unsatisfied with the resolution of your complaint, you may contact JAMS at 7160 Rafael Rivera Way, Suite #400, Las Vegas, NV 89113, attention:  Mara E. Satterthwaite, Esq. or visit https://www.jamsadr.com/DPF-Dispute-Resolution for further information and assistance.

Binding Arbitration.  If your DPF 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 Data Privacy Framework Annex 1 at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

Contact Us

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows:  McDonough Corporation, 21050 North Pima Road, Suite 100, Scottsdale, AZ 85255, attention:  Brian O’Brien, Chief Financial Officer.  You may also contact us via email at:  bobrien@marmac.net. 

Changes To This Policy

This Policy may be amended from time to time, consistent with the requirements of the DPF Principles.

Effective Date:  June 3, 2024