Con-way's Safe Harbor Privacy Policy

Con-way is strongly committed to protecting the privacy of those who entrust us with their personal information. With regard to personal information, Con-way respects the privacy of our employees and all those who do business with us.

In furtherance of our commitment, Con-way has certified to the Safe Harbor Agreement between the United States and the European Union, with respect to personal data that we process. Accordingly, Con-way adheres to the Safe Harbor privacy principles and Frequently Asked Questions, as agreed upon by the U.S. Department of Commerce and the European Commission (the "Safe Harbor Principles").

This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Con-way follows when handling any personal data, either collected or received for the purposes of managing our workforce and conducting our business, where such personal data is transferred from countries within the European Economic Area (EEA) to the United States.

Definitions

"Con-way" means Con-way Inc. and all of its subsidiary companies.

"Agent" means a third party that processes personal information solely on behalf of and under the instructions of Con-way.

"Personal information" means any information or set of information that identifies or can reasonably be used to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. Information that is received from a third party that treats and identifies it as sensitive will be treated as sensitive personal information by Con-way.

Privacy Principles

NOTICE: Con-way will inform individuals about the purposes for which we collect and use personal information about them, the types of non-agent third parties with which we share such personal information, and the choices and means we offer for limiting the use and sharing of personal information. The notice will be clear and conspicuous and will be provided either when individuals are first asked to provide personal information or as soon thereafter as is practicable.

CHOICE: Con-way will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) shared with a non-agent third party, or (b) used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Con-way will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of their information to a non-agent third party or use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

ONWARD TRANSFERS: Where Con-way transfers personal information to an agent, Con-way will obtain assurances from such agent that they provide at least the same level of privacy protection as is required by these privacy principles. Con-way will only transfer personal information to a non-agent third party where consistent with the notice provided to the individuals who are the subject of the data and any consent that those individuals have given.

ACCESS: Upon request, Con-way will provide individuals reasonable access to personal information about themselves and will take reasonable steps to permit individuals to correct, amend, or delete personal information that they demonstrate to be inaccurate or incomplete.

SECURITY: Con-way will take reasonable precautions to protect personal information in its possession from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

DATA INTEGRITY: Con-way will only use and share personal information in ways that are relevant for the purposes for which this information was collected or subsequently authorized by the individual. Con-way will take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete, and current.

ENFORCEMENT: Con-way will conduct periodic, internal compliance audits of its relevant privacy practices to verify adherence to these privacy principles. Con-way encourages individuals covered by this Policy to raise any concerns they have about the way we process their personal data by contacting us at the address below or by calling the Con-way Ethics hotline. We will do our best to resolve any concerns brought to our attention. In the event we cannot resolve a concern involving an individual's personal information, Con-way has agreed to participate in the dispute resolution program provided by the European Data Protection Authorities Panel.

Limitation on Scope of Privacy Principles

Adherence by Con-way to these privacy principles may be limited to the extent required to meet a legal, governmental, national security, or public interest obligation.

How to Contact Us

Questions or comments regarding our Safe Harbor certification should be submitted to Con-way by mail or email as follows:
Con-way Enterprise Services Inc.
1717 NW 21st Ave.
Portland, Oregon 97209
Attn: Legal Department

Employees may also raise concerns regarding Con-way’s handling of personal information by calling the Con-way Ethics hotline, reporting such concerns online at www.ethicspoint.com, or by calling Con-way’s Corporate Compliance Office.

Changes to this Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. When amendments are made, we will revise the "last updated" date at the bottom of this Policy.

Last updated February 17, 2012

 
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