Privacy Policy

Your privacy is very important to us. This Privacy Policy discloses how Zaibak Brothers & Company (“ZBC”) collects, protects, uses and shares personal information gathered about you. All personal information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. ZBC respects the privacy of our customers and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protection and management of personal information that you provide to us. This Privacy Policy will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared. In an effort to comply with the law, and our commitment to protect your personal information, we provide the following, which discloses our policies.

What type of information do we collect?

Personal Information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to a Social Security Number and/or Identification Number (hereinafter “SSN/I.N”) or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Personal Information shall include but is not limited to: name, home address, home telephone number, email address, SSN/I.N., financial information and employment related information such as may be found on resumes, applications, background verification information, or in employment references.

ZBC takes measures to maintain the confidentiality of your SSN/I.N. to protect your SSN/I.N from unlawful disclosure, and to limit access to your SSN/I.N. ZBC will not make your SSN/I.N available to the general public, print your SSN/I.N on any card, require you to provide your SSN/I.N to access any products or services, transmit your SSN/I.N over the Internet unless the connection is secure or your SSN/I.N has been encrypted, or requires the transmittal of your SSN/I.N to access our Website without requiring additional authentication.

Non-personal information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number.

We will never collect sensitive Personal Information except to comply with Affirmative Action data requirements. Sensitive Personal Information can include but is not limited to: information pertaining to gender, disabilities, and veteran status.

Cookies – Internet Users

In addition to Personal Information, we use data collection devices such as “cookies” on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.

Children and Data Collection

ZBC adheres to the federal privacy protection standards as stated in the Children’s Online Privacy Protection Act (“COPPA”). We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 13 years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately at privacyofficer@zaibakbrothers.com. We will use reasonable efforts to promptly delete the child’s information from our servers.

Our Use of Your Information

We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately inform you of the use of your Personal Information.

Collection and Use of ZBC’s Customer Information

ZBC will not collect customer Personal Information, unless the customer contacts ZBC directly. In order to adequately address a customer’s concern, their Personal Information may be shared with our affiliated third parties. Failure to provide necessary information may prevent ZBC from fully addressing any customer concerns.

Sharing of Personal Information

We may share Personal Information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Policy, ZBC will not share Personal Information with a third party, unless a customer requests, consents to such disclosure, or disclosure is required or authorized by law. ZBC reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so. ZBC also reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of ZBC or of any of the business or assets or shares of ZBC or a division thereof in order for a customer to continue to receive the same products and services from the third party.

Security

We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.

We safeguard your Personal Information on the Internet by using industry-standard practices. Although “guaranteed security” does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your Personal Information.

Currently, our website utilizes a variety of different security measures designed to protect Personal Information of users both inside and outside ZBC, including the use of encryption mechanisms (e.g., Secure Socket Layers or SSLs), password protection, and other security measures to help prevent unauthorized access to your personally identifiable information. This helps maintain the confidentiality, privacy, and integrity of your transactions, and helps to protect your confidential information – such as credit card numbers, online forms, and financial data from loss, misuse, interception and hacking.

Storage, Retention and Accuracy of Personal Information

ZBC insures that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.

ZBC will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose remains valid after termination of our relationship with you.

We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

Contact Information

You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another employee to assist in completing your requested task.

If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at: (312) 564-5800; by Facsimile at: (312) 376-1849; by email at: privacyofficer@zaibakbrothers.com; or by mail at Zaibak Brothers & Company, 35 E. Wacker Drive, 9th Floor, Chicago, Illinois, USA. We will address your concern and attempt to resolve any problem.

Links to Non-ZBC Web Sites and Third Parties

Please note that www.zaibakbrothers.com may contain links to other web sites for your convenience and information. ZBC does not control those sites or their privacy practices, which may differ from www.zaibakbrothers.com. ZBC’s privacy policy cannot and does not apply to external websites. We do not endorse or make any representations about third party web sites. The personal data you choose to give to unrelated third parties is not covered by the ZBC privacy policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third parties may choose to share their personal data with ZBC; that sharing is governed by that third party company’s privacy policy.

Changes to our Privacy Policy

ZBC will update this Privacy Policy occasionally. When ZBC posts changes to this Privacy Policy, we will also revise the “Last Updated” date below on ZBC’s Privacy Policy. If there are material changes to this Privacy Policy, ZBC will notify you by email, or by means of a notice on our home page. ZBC encourages you to review this Privacy Policy periodically to be informed of how ZBC is protecting your information and to be aware of any changes to the Privacy Policy. Your continued use of the site after the posting of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. This Privacy Policy is incorporated into any Terms and Conditions governing the various websites and any programs or services operated or managed on or behalf of ZBC. Any changes to this Privacy Policy are effective immediately after being posted by ZBC.

LAST UPDATED: 04/25/11