1. What we collect:
We may collect the following Personal Information when you create an account or sign up to receive our newsletter:
- name and job title (if relevant)
- contact information including email address
We may collect the following Personal Information when you use our services, purchase a product, or send a query, comment or other feedback to us
- name and job title (if relevant)
- contact information including email address
- billing address
- products purchased
- services undertaken
- other information that would be useful or necessary to process your purchase
It is always your choice whether to provide personal information to us and by doing so, you acknowledge and agree that you are giving us your consent to use that information to respond to your requests, to provide customer support, to contact you and to provide information about our products, services and opportunities (see further: What we do with the Information we gather below). In relation to personal information provided by you in connection with a job listing, we will use that information for the purpose of assessing your application.
We may also automatically collect non-personal or clickstream information (“Anonymous Information”) from you when you access our Website. This can include, the type of browser you are using, the address of the website from which your visit originated, your IP address, the operating system you are using, the domain name of your Internet service provider, the pages you visit on our Website, and the duration of your visit.
If you have liked us on Facebook or interact with us through other social media sites, we may have access to some Personal Information about you (e.g. your name and the posts you have liked) that is made available on those Third Party sites. We will only use that data in an aggregated fashion to review and improve the Website and our services.
2. What we do with the Information we gather:
The Personal and Anonymous Information we gather from you through use of our services, and/or on our Website helps us learn about visitors to the Site, our customers and potential customers. We use this information to personalize your experience, to better tailor the features, performance and support of our products and services, respond to inquiries and requests that you make. Additionally, for registered users of the Website, the Personal and Anonymous Information (collectively “Information”) we gather from you is used to set up secure user access and account to the Website. All such collected Information is used for the following reasons:
- Internal record keeping.
- We may use the Information to improve our products and services, to process your transactions, to provide customer service, to perform research and analysis aimed at improving our products, services and technologies, and to display content that is customized to your interests and preferences.
- We may periodically send promotional emails, newsletters, or other communications about new products, services, special offers or other information which we think you may find interesting using the email address or other contact information which you have provided when you registered or signed up for our services
- We may also send you surveys, newsletters or marketing emails to inform you of new products or services or other information that may be of interest. If you do not wish to receive marketing emails, you may follow the “unsubscribe” instructions included within each email communication.
- From time to time, we may also use your Information to contact you for market research purposes. We may contact you by email, phone, fax or mail.
- We may use the Information to customize the Website according to your interests.
- We may provide your Information to our third party partners for marketing or promotional purposes.
- We may share your Information with service providers who perform services on our behalf. For example, Information may be shared when we may engage third party companies and individuals to facilitate our Website, and to perform Website-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Website’ features) or to assist us in analysing how our Website is used.
- We may share your Information within our corporate group, including with our subsidiaries and divisions, all of whom may use your information for the purposes disclosed herein.
- Information about our customers, including Personal and Anonymous Information, may be disclosed as part of any merger, acquisition, or sale of the company and/or its assets, as well as in the unlikely event of insolvency, bankruptcy, or receivership, in which Personal and Anonymous Information would be transferred as one of the business assets of the company.
- We reserve the right to disclose your Information if required to do so by law (including to meet national security or law enforcement requirements), or in the good-faith belief that such action is reasonably necessary to comply with legal process, respond to claims, or protect the rights, property or safety of our company, employees, customers, or the public.
The security of your Personal Information is important to us. We follow generally accepted industry standards to help protect your Personal Information, and in order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Our security procedures mean that we may occasionally request proof of identity before we disclose any personal information to you.
You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, remember to log out of your account and close your browser window when you have finished using the Website.
No method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to protect your Personal Information, we cannot guarantee that such information will not be lost, disclosed or accessed by accidental circumstances or by the unauthorized acts of others.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit the particular Sites. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Cookies allows us to operate your shopping cart, to identify registered users when they return to the Site so that they can retrieve previous search results, access carts etc. We also use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs and is used for statistical analysis purposes.
5. Cookies offer you many conveniences:
- They keep track of your shopping cart (where applicable)
- They allow us to identify registered users when they return to the Site so that they can retrieve previous search results and shopping carts (where applicable).
- Cookies save you time by eliminating the need to repeatedly enter the same information.
- Cookies allow us to deliver personalized content to you, including search results and interest-based targeted content
- Cookies help to protect your security by checking your login details and may help prevent fraud.
- Cookies remember your preferences when using the Sites.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website, as it will disable the ability for the site to recognise your cart, your account and any personalization efforts.
6. Links to other websites:
Our Website may contain links to enable you to visit other third party websites, including social media networks. We are not responsible for the content, security, or privacy policies of such third party website and networks. No warranty is made with respect to other sites or networks, their security, or the content they contain, and we take no responsibility for them. Any use you make of the information provided on the Sites, or any sites or service linked to by the Sites, is at your own risk. You should exercise caution and look at the privacy statement applicable to the third party website in question.
7. Accessing and Controlling your Personal Information:
You may choose to restrict the collection or use of your Personal Information in the following ways:
- if you have previously agreed to us using your Personal Information for direct marketing purposes, you may change your mind at any time by writing to or emailing our Privacy Officer at email@example.com
- We offer you choices regarding the collection, use and sharing of your Personal Information. When you receive daily updates or newsletters, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly at firstname.lastname@example.org
- Where provided under applicable law, you have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and may ask about all recipients of the Personal Information, the purpose of the processing and to have a general account of our uses of that information Upon receipt of your written request to email@example.com, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavour to deal with all requests for access and modifications in a timely manner. We may require you to prove your identity with approved identification if you request this information.
- If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
- You have the right, where provided under applicable law, to ask us not to process your Personal Information for direct marketing purposes. You can exercise your right to prevent such processing by clicking “unsubscribe” on the emails you receive. You can also exercise the right at any time by contacting our Privacy Officer at firstname.lastname@example.org
The Website is not directed at anyone under the age of 18 and we do not intend to solicit or collect Personal Information from anyone under the age of 18. If you are under 18, you should not use or enter information on the Sites. We do not knowingly collect Personal Information from anyone under the age of 18. If you are under the age of 18, do not use the Website without the supervision of your parent or guardian. If you have any questions, please contact us at email@example.com
9. Storage and Transfer of Information:
On July 16, 2020, the Court of Justice of the European Union (CJEU) confirmed that Standard Contractual Clauses (SCCs) remain an acceptable method to transfer personal data outside of the EU/EEA. Standard Contractual Clauses (SCCs) are another method to transfer personal data lawfully outside the EU and ensure that personal data remains protected in accordance with EU law. They consist of non-negotiable language approved by the European Commission for agreements governing the transfer of personal data outside the EU. They may also be used to transfer data to the US. Where data is transferred, we ensure that any service providers that have access to that data are compliant with the SCC to ensure that this is a legal basis for any transfer.
By submitting Anonymous and Personal Information, using our services and/or using our Website, you agree to this transfer, storing and/or processing.
12. Contact Information:
If you have any questions or concerns regarding this privacy statement and/or our practices in relation to data, please contact us at firstname.lastname@example.org
13. Notice to California Customers – Your Privacy Rights
The California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), grants residents of California certain rights with respect to their Personal Information and requires us to provide such individuals with certain information, described in this section.
California residents may contact our Privacy Officer by email at email@example.com if you want to
- Know the methods in which we acquire, use, share, disclose or otherwise process your Personal Information
- Know which pieces of your Personal Information that we hold and receive a copy of that data
- Request deletion of your Personal Information, subject to several exceptions
No California resident can be discriminated against for exercising these rights. You should note that where certain technologies rely on your data to provide the Website, the absence of that data may impact the Websites operation.
California residents also have the right to opt-out of the sale of their Personal Information. We do not sell any personal information (money does not change hands), but we do exchange anonymous information with Third Party Businesses to further their own commercial purposes such as generating profiles about individuals. This is anonymous information such as online identifiers, Devices IDs and other information about your use of the site in order to better target information to you, which could be considered value under the CCPA. As a result, California residents can opt out by emailing firstname.lastname@example.org. Note that we can still share Personal Information with our Service Providers if that transfer is not a sale.
Depending on the circumstances and which Service you use, we have disclosed the following categories of your Personal Information for a “business purpose” (as defined in the CCPA) in the preceding twelve (12) months:
- Protected characteristics
- Commercial information (limited to information entered to purchase a product from our site)
- Geolocation data
- Internet or other electronic network activity information
- Financial information (limited to information entered to purchase a product from our site, if available)
- Inferences drawn from any of the above information categories.
Depending on the circumstances and which Service you use, we have transferred the following categories of your Personal Data to Third Party Providers (and hence count as a Sale as defined in the CCPA) in the preceding twelve (12) months:
- Commercial information (limited to information entered to purchase a product from our site, if available)
- Geolocation data
- Internet or other electronic network activity information
- Inferences drawn from any of the above information categories
14 Preventing Disclosure for the Purposes of Marketing
California’s "Shine the Light" law, Civil Code Section 1798.83, gives California customers the right to prevent our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes. We do not sell any Personal Information but we do exchange anonymous information with Third Party Businesses to further their own commercial purposes such as generating profiles about individuals. This is anonymous information such as online identifiers, Devices IDs and other information about your use of the site in order to better target information to you, which could be considered value under the CCPA. As a result, California residents can opt out by emailing email@example.com.
15. Notice to European Customers – Your Privacy Rights
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, personal data;
- If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of your personal data in a usable and portable format;
- If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
- You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, contact us at firstname.lastname@example.org. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns. Please be aware that those rights set out above may not apply in some instances, for example where our right to processing your personal data may be necessary for the establishment, exercise or defense of legal claims.