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Last updated: May 8, 2020
1. Whose Personal Information Do We Collect
The Company collects personal information from a range of individuals in the context of our business activities, including from the following: customers; individuals that use, or otherwise access, our Site; individuals who visit our premises or facilities; representatives of our suppliers, customers and other business contacts; contractors and similar types of workers; individuals related to, or otherwise affiliated with, our Company’s employees; and, individuals who contact us by any means.
2. The Types and Categories of Personal Information We Collect
The type of personal information that the Company collects depends on our relationship with the particular individual. Generally, we collect the following types and categories of personal information:
When you do not provide personal information that the Company requests, we may not be able to provide you the requested service or complete a transaction, and you agree that the Company will not be liable or otherwise responsible for any damages or loss arising from such circumstances.
3. How We Collect Personal Information
Most often, the Company obtains personal information directly from the individual. For example, when an individual undertakes the following activities, we generally collect their personal information:
In accordance with applicable law, we may collect personal information about you from third parties, such as social media websites/applications, former employers, background check providers, and others, which we may combine with the information we already hold about you in order to promote our legal or business interests, such as to help us improve and customize our Site. We may also collect your business contact information from your employer or other third parties, which we will use to facilitate or otherwise engage in traditional business activities and similar administrative matters. We may also ask you to provide personal information about third parties to use as references, answer questions about your employment, or for other reasons. If you provide personal information about a third-party you expressly represent and warrant to the Company that you have the full right and lawful authority to provide the Company with the information.
4. How We Use your Information
The Company may use personal information for several business and administrative purposes, or to further our legal or other business interests. Generally, we use personal information for the following reasons:
5. Sharing Information and Third-Party Disclosures
We may share your personal information with selected third parties in accordance with applicable law, including as set forth below.
In the event that you facilitate a transaction with the Company, or request information from, or otherwise engage with us, and such activities require the Company (in our sole judgment) to share your personal information with a service provider or other third-party, you hereby direct the Company to intentionally disclose your personal information to the service provider or third-party as described herein provided the service provider or third-party does not, in its reasonable judgment, sell the personal information, unless that disclosure would be consistent with the law.
6. Links to Other Websites
7. Data Retention and Localization
The Company is based in, and has regional offices across, the United States. The information that the Company collects and processes is retained and stored in the United States, and the Company does not participate in the U.S. Privacy Shield Frameworks. In some circumstances, the Company uses third-party service providers that retain information and data on behalf of the Company in the United States and in other third countries. Please be aware that information you provide to the Company may be transferred to the United States or a third country, and that the United States and other third countries may not provide the same level of data protection as the laws in your country. By continuing to provide us such information you hereby consent to your personal information being transferred to, and stored in, the United States or any other third country outside your country of residence.
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. However, no information system can be fully secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to the Site over networks that we do not control, including the Internet and wireless networks, and you provide us with any information and data at your own risk. To the extent permitted by law, the Company shall not be liable or otherwise responsible for any data incidents that may compromise the confidentiality, integrity, or security of your personal information. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a user name and password to access the Site, you are responsible for maintaining the security and confidentiality of those log-on credentials and not revealing them to others. You must contact us immediately if you have to reason to believe that your user names or password to our Site have been compromised.
9. No Data Collected from Children
Our Site is not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under eighteen years of age with or without consent from their parents or guardians. If you are under the age of eighteen you are hereby prohibited from using our Site or with providing us with your personal information, unless you can demonstrate affirmative authorization from your parent or legal guardian to do so and thereafter we grant you written consent.
10. Cookies, Analytics, and Ads
We use different analytic tools which serve the purpose of measuring, analyzing and optimizing our Site’s performance, marketing purposes, and, for providing you with customized advertisements that could be of particular interest to you. For example, the Sites use tools and programs from the following sources:
You can find more information about cookies and behavioral advertising at http://www.allaboutcookies.org/.
11. Your Rights and Responsibilities
Depending on the jurisdiction in which you reside or the Company operates, you may have certain data protection rights. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. In the event you submit, or your authorized agent submits on your behalf, a data request, you (and your authorized agent) hereby acknowledge and agree, under penalty of perjury, that you are (or the authorized agent of) the consumer whose personal information is the subject of the request. We will respond to any data requests within the timeframes required by law, and we may charge a fee to facilitate your request, where permitted by law. The rights afforded under data protection laws are not absolute, and the Company may be permitted to refrain from undertaking any action or changing its data processing activities, in response to a data request you submit to us.
Email Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an “unsubscribe” option of not receiving such communications from us in the future.
Text Message/SMS Marketing. If you agree to receive text messages from the Company or our service providers to receive marketing and similar alerts, your hereby consent to the sending and receipt of such text messages to the mobile number provided using an automatic telephone dialing system. In providing this consent, you understand that (i) you are not required to grant consent as a condition of making purchases or receiving services from us, (ii) you may revoke your consent at any time by replying to any the text alert or message with the word “STOP” or by contacting us in accordance with the “Contact Us” section listed below, and (iii) standard message and/or data rates apply to such alerts and messages. You further agree to immediately contact the Company (in accordance with the “Contact Us” section listed below) in the event the mobile number you provided us to receive text messages is no longer active or under an account in which you have the authority to consent to receiving such text messages and will indemnify and hold harmless the Company for any losses or damages due to breaches of any of the foregoing.
California Privacy Rights. California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties with whom we have reason to believe use such information for their own direct marketing purposes. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), certain California residents may have additional data privacy rights, such as the right to be notified about what personal information is collected about you, and our intended use and purpose for collecting your personal information. In some circumstances, California residents have the right to know and access the categories or specific pieces of personal information we have collected, used, or disclosed about you over the past twelve (12) months; the categories of sources from which the personal information is collected; and, the business or commercial purpose for which your personal information was collected, used, or disclosed. In addition, certain California residents have the right to request the Company transfer, to the extent feasible, personal information in certain forms and formats. California residents have the right to request that we (and any applicable service provider) delete/erase your personal information under certain circumstances. California residents have the right to opt-out of the sale of their personal information, and the Company does not sell, lease, or rent personal information on any individual, including minors, to a third-party for profit or other valuable consideration. California residents have the right not to be subject to discrimination for asserting their rights under the CCPA. If you make, or an authorized agent on your behalf makes, any request related to your personal information under the CCPA, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required under the law before addressing your request. The Company may require you to match at least two or three pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces, or categories of, personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third-party is authorized to serve as your agent for the purposes of submitting the requests set forth herein.
Do Not Track. Some web browsers may transmit “Do Not Track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
12. Rewards and Calculating Rewards Points
Pursuant to certain data protection laws, such as the California Consumer Privacy Act, individuals may be entitled to be informed as to why financial incentive programs, or price or service differences, are permitted under the law, including (i) a good-faith estimate of the value of the individual’s personal information that forms the basis for offering the financial incentive or price or service difference, and (ii) a description of the method the business used to calculate the value of the individual’s personally identifiable information. Generally, the Company does not assign monetary or other value to personal information we collect and retain. However, in the event we are required by law to assign such value in the context of financial incentive programs, or price or service differences, the Company has valued the personal information it collects and uses as being equal to the value of the discount or financial incentive provided, and the calculation of the value is based upon a practical and good-faith effort often involving the (i) categories of personal information collected (e.g., names, email address), (ii) the transferability of such personal information within the Company and our programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in the program, and (v) the product or service to which the financial incentive programs, or price or service differences applies. [The disclosure of the value described herein is not intended to waive, nor should be interpreted as a waiver to, the Company’s proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.]
13. Changes to the Policy
14. Contact Us
15. Effective and Amendment Date