Privacy Statement

The Ironworker Management Progressive Action Cooperative Trust ("IMPACT", "we" or "us") appreciates your interest in our services and your visit to the Safety Management Database System ("Site" or "SMDS") pursuant to the IMPACT Drug Free Workforce Program (http://www.impact-net.org/member-programs/ironworkers/impact-drug-free-workforce). IMPACT uses one or more third parties to host and service this site. Below is a detailed accounting of what information we collect from users of our Site, how we collect that information, how we use that information, how we ensure that information is not misused, and what control users of the Site have over the information. This statement supplements the privacy information present in the Site's Terms of Use agreement.

COLLECTED INFORMATION

We collect information from registered users of the Site through a variety of mechanisms. Some of these mechanisms are apparent to our users and some are not.

Apparent Information Collection

During the use of the SMDS, we collect two classes of information, "Service Content" and "User Content". Service Content is any materials, files, communications, and documents posted by users in conjunction with the service. This includes things like drug test results uploaded. All other user-supplied information, excluding the Service Content, is referred to as User Content. This includes things like the information provided when setting up a user account with our Site. Most User Content in the SMDS is provided by automatic feeds from the International Ironworkers member database or the IMPACT website.

Two subclasses of User Content that we collect are "Contact Information" and "Billing Information". Contact Information is collected from all registered users of its services. This information includes some or all of the following: user's full name, username, password, phone number and/or e-mail address. We collect Billing Information for each company listed on the Site. Billing Information consists of information such as a billing contact name, a company name, mailing address, and telephone number.

Non-Apparent Information Collection

We also collect information about users that is implicitly supplied by users during their use of the Site. This information is saved in Log Files and Database Tables on SMDS servers, and in Cookies on a user's client computer. We track what, when, by whom, and from where Service Content is created, deleted, downloaded, uploaded, and viewed. We also track when users become registered, deregistered, and when registered users log into a service.

COOKIES

Regarding cookies, we reserve the right to collect various information through the use of computer “cookies” or data files which recognize your computer or device when you return to our site or re-use our mobile application. You may instruct your computer or device to refuse these cookies, but this is likely to impair or impede the service we are able to provide you. IMPACT uses them solely to make using the Site more efficient for users. IMPACT does NOT presently use cookies to track user activity on the Site, but may do so in the future.

INFORMATION SHARING

As described below and in this Site's Terms of Use, IMPACT uses the services of one or more third parties to create and maintain this website and provide related services, and information which you submit will necessarily be shared with and retained by them.

In general, IMPACT may access all Apparent and Non-Apparent information we collect in order to:

• perform system administration
• respond to court orders
• comply with legislation
• investigate complaints
• protect others from liability or damage
• perform relevant services

IMPACT does not share any information it collects with third parties other than those stated below and third party hosting services contracted to complete any or all of its services.

Service Content and User Content

In general, content is shared among users of the SMDS. The user permission structure for this Site is available upon request to approved users by emailing support@copperrange.com.

Service Content or User Content is shared with third party providers of credentials (such as a Drug Testing Company, as chosen by IMPACT) in order to connect any results with the user when information is returned to our Site or to assist the third party in managing the creation of the credential in question. The content shared for this purpose could be any combination of the following: the name of the user or name of the worker a user is managing, a unique identifying number, reason for a drug test authorization, the person’s employer and/or union local affiliation, and billing/contact information at the employer and/or union local.

Service Content and User Content is shared with programs participating in the Worker Exchange System. With IMPACT approval, users of the Worker Exchange System can search for an Employee's Worker Credentials when they provide a Member Number, name, and/or other identifying number. Worker Credentials include the Employee's name, Member Number, Drug Test Status, and any other credentials entered in to the Site.

In general, IMPACT uses Billing and Contact information only to effect billing that may take place between us and our registered users, and to alert our registered users of new services or changes to existing services. IMPACT and our Hosting Services also use Service Content and User Content to provide customer support to current users of the Site.

Non-Apparent Information

The Non-Apparent Information that IMPACT collects is used to serve as a means to resolve disputes that may arise among registered users or between registered users and IMPACT.

INFORMATION USE AND RETENTION

While we do not presently do so, we reserve the right to freely utilize and share for marketing, product development and other lawful purposes (possibly for a fee) with actual and potential business partners all information which we collect. It is anticipated that your information will be transmitted across national boundaries, if you desire that we not share any information, please contact us at privacy@copperrange.com so that we can record your preferences. However, it may not be possible for us to continue provision of services absent such sharing. Information shall be retained so long as needed for provision of contemplated services and otherwise as legally required from time to time as determined by IMPACT Management.

CERTAIN CONSENT AND RIGHT TO OBJECT

If you are a California resident, to the extent provided under California law, you may object in writing to our sale or other sharing of your personal information and we will refrain from doing so, without an economic impact on you, except to the extent, if any, that our inability to make use of your data impacts the economic value of our business relationship.

• Your information will be shared with third parties.
• Your information may be transmitted across national boundaries to and from the United States and other countries.
• You are aware of your right to object to the processing of information and will proceed in accordance with this Policy in order to object.
• You are aware of the collection and further processing of various information about you in order to provide the services and opportunities of the SMDS
• You are aware of your right to withdraw this consent at any time.
• You are aware of your right to access, modify and delete data pursuant to notice to privacy@copperrange.com.
• We will place ‘cookies’ on your computer or mobile device.

RISK OF SECURITY BREACHES

While we believe and intend that our information security practices reflect good practice, there is no such thing as perfect information security. Therefore, users assume the risk of security breaches and all consequences resulting from them. Additionally, users must safeguard their credentials. We assume no liability for any unauthorized access by a third party to any information or database maintained by or for us or with respect to the services which we provide.

LINKED SITES

This Site does contain links to other websites. We have no control over their operation and/or the accuracy of any statements made on them and assume no responsibility with respect to them or their legal compliance.

CHILDREN'S PRIVACY

We do not knowingly collect Personal Information from children under the age of 16 and do not allow access by such persons. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.

CALIFORNIA RESIDENTS AND DO NOT TRACK REQUESTS

California residents may request a list of all third parties with respect to which IMPACT has disclosed any information about you. If you are a California resident and want such a list or desire that we not maintain or utilize a record of your internet usage or path to our site, please send us a written request by e-mail or US mail to privacy@copperrange.com or 1750 New York Avenue, Fourth Floor, Washington, DC 20006. Include “Your California Privacy Rights” in the subject line of your e-mail or on the envelope or post card and in the body of your request. Please include your name and full contact information. We will use our best efforts to accommodate. We do not necessarily take any specific technical measures to respond to ‘Do Not Track’ settings in your internet browser.

AMENDMENT

We reserve the right to amend this policy at any time in our sole discretion and to the extent required for compliance with applicable law and interpretation from time to time, and any such amendments shall apply to information already collected and to be collected.

DISPUTE RESOLUTION AND CHOICE OF LAW

Except as otherwise required by law, any disputes regarding this Policy shall be resolved through arbitration in accordance with District of Columbia law and the rules of the American Arbitration Association in the District of Columbia.

BUSINESS ACQUISTION

If our business is acquired in whole or part by another company, then personal information maintained by us may be disclosed to them, but that disclosure will be subject to this policy.