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Privacy Policy |
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Last Updated: November 30, 2023 PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND TO OUR APPLICABLE WEBSITE TERMS OF SERVICE AND COOKIE POLICY. YOU HEREBY AGREE THAT ANY AND ALL COMPLAINTS, CLAIMS, OR DISPUTES ARISING FROM THE USE OF YOUR PERSONAL INFORMATION AND/OR THE SERVICES WILL BE SETTLED IN ACCORDANCE WITH OUR TERMS OF SERVICE, INCLUDING THE LIMITATIONS OF LIABILITY AND ARBITRATION TERMS SET FORTH THEREIN. 1. DEFINITIONS AND SCOPE This Privacy Policy applies to personal information that the Company processes during its business operations as a data controller, which means we determine the purpose and means of processing such personal information. For purposes of this Privacy Policy, the term "personal information" means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term "personal information" does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and that is not otherwise subject to a data protection law, statute, or regulation. The Company may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and the Company may use such data for any purpose. 2. THE TYPES OF PERSONAL INFORMATION WE COLLECT The type and categories of personal information that the Company collects varies based on the nature and scope of our business activities. When you do not provide personal information that the Company requests, we may not be able to provide you our Services 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. Generally, we collect the following types and categories of personal information from users of our Services or as part of our business
Technical Data In addition to the foregoing, when you use our Sites and/or Services, we collect and use additional data and tools, including usage data, metadata, location data, and cookies and tracking technologies (collectively, "Technical Data"), which is described below. The Services collect Technical Data on a consistent and reoccurring basis, unless your device settings are updated to prevent such collection. We use this Technical Data in accordance with the terms and disclosures set forth in this Privacy Policy. Usage Data. When you access and use the Services, we may automatically collect details of your access to and use of the Services, including traffic data, usage logs, and other communication data, and the resources that you access and use on or through the Services (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device's unique device identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Services may collect diagnostic-related data related to your use of the Services, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics. Location Data. When you access and use the Services, we may collect information and data identifying the precise, real-time location of the device that is used to access or use the Services. You can choose whether or not to allow the Services to collect and use information about your device's location. If you block the use of location information, some parts of the Services may become inaccessible or not function properly. Cookies and Tracking Technologies. We use cookies and other tracking technologies within the Services. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Services may become inaccessible or not function properly. In addition, the Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on the users of the Services (e.g., recording the popularity of certain content and verifying system and server integrity). For information, see our Cookie Policy. Non-Cookie Technologies. We may deploy on our Sites certain types of "Non-Cookie Technologies" provided by our service providers to support our digital advertising programs. These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically or with additional data specifically requested from your browser or device. For more information, see https://thenai.org/wpcontent/ uploads/2021/07/NAI_BeyondCookies_NL.pdf. Site Monitoring. Please be aware that we, and our service providers and marketing partners, deploy cookies and other tracking technologies on and within our Site to monitor and record activities and communications to, from, and on, the Site in order to safeguard, improve, and analyze usage of, the Site, and for the other purposes listed in this Cookie Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording by us, and our service providers and marketing partners. Audio and Visual Materials. Our Sites may, from time to time, display live or prerecorded videos or similar audio visual materials ("Videos"). We may collect personal information with respect to you requesting access to, and/or accessing, such Videos, and we may disclose such personal information to third parties, including to our third-party service providers through the use of cookies. The provision of Videos on our Sited is not an admission by the Company, and it shall not otherwise be interpreted, in any form or manner, to mean that the Company is a "video tape service provider" for purposes of the Video Privacy Protection Act (codified as amended at 18 U.S. Code § 2710) (the "VPPA") or that the Company is otherwise subject to the VPPA. Other Recordings. WE, AND OUR SERVICE PROVIDERS AND BUSINESS PARTNERS, MAY RECORD CALLS AND RETAIN THE CONTENT OF CHAT TRANSCRIPTS, EMAILS, TEXT MESSAGES, AND OTHER WRITTEN OR ELECTRONIC COMMUNICATIONS BETWEEN YOU AND US. 3. VIDEO TELECONFERENCING The Company hosts, and uses video teleconferencing ("VTC") platforms to facilitate our Services, and host conferences, meetings, training events, and the VTC platforms may be owned and administered by a third-party service provider (e.g., Zoom, WebEx, Skype for Business). Please be aware that the VTC platforms may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in the VTC platforms, you hereby consent to the collection and retention of any information and content provided therein, and hereby consent to the recording of such activities. 4. HOW WE COLLECT PERSONAL INFORMATION/SOURCES The Company obtains your personal information directly from you when you provide it to us (i.e., direct collection) and from third parties (i.e., indirect collection), which includes the following: Direct Collection. We often collect personal information directly from you when you undertake the following activities: use or access our Services; complete one of our web forms; contact our customer service centers or request information from us in any other way; visit one of our locations or premises; submit an order or make a purchase with us; provide us contact information via a business card or through similar communications; complete a survey or otherwise provide us feedback; report product/service issues; communicate with us via social networking websites, third-party applications, or similar technologies; and/or visit, one of our trade counters at an exhibition. We automatically collect information from you when you access and us our Site (see Technical Data, above). Indirect Collection. We may collect personal information about you from third parties, which we may combine with other information we already retain in order to provide the Services or promote our legal or business interests. For example, we may collect personal information about you from publicly available social medial platforms and employers may provide us with personal information and other background data on job applicants so we can assist with our employment recruitment process. 5. HOW WE USE YOUR INFORMATION We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests, including to (i) provide, operate, maintain, improve, and promote our Services, (ii) enable you to access and use our Services, (iii) process and complete transactions, and send you related information, including purchase confirmations and invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for our Services, (v) furnish technical notices, updates, security alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events), (vii) process and deliver contest or sweepstakes entries and rewards, (viii) monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests (e.g., marketing), (ix) investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities, and (x) personalize our Services, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, Company may collect and use your personal information for any other purpose for which we obtain your consent. For the avoidance of doubt, you hereby agree that Company may contact you via any means, including SMS/text message and email, to furnish you information regarding a product order, shipping status, warranty-related information, and similar data and information pertaining to a commercial transaction. Mobile Messaging Program. In the event you opt-in to our Mobile Messaging Program, we will collect and use your mobile telephone number to maintain and administer our Mobile Messaging Program. Please review our SMS Terms and Conditions for more information, including information on how to unsubscribe or update your personal information therein and your responsibilities and liabilities related thereto. 6. SHARING YOUR PERSONAL INFORMATION WITH OTHERS We do not sell, lease, or rent your personal information to a third party for profit or other valuable consideration. We may, however, share your personal information with selected third parties for our business purposes, including as set forth in this Privacy Policy. In addition, we may also share your personal information as follows: Corporate Group Sharing. We share personal information within the Company, such as among our affiliates and subsidiaries who act for the Company or on behalf of our parent company and these recipients may use your personal information in accordance with the terms and conditions of this Privacy Policy or their own data privacy representations. In addition to the foregoing, the Company may leverage computer networks and systems of our parent company, affiliates, and subsidiaries and the personal information may be transmitted or retained thereon. Service Providers. We share information, including personal information, with our third-party service providers that support our Services, such as with respect to product delivery, application development, data backup and storage, payment processing, marketing and consumer analytics, and information technology support. Business Partners. In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. We may partner with trusted third parties to provide you with comarketing content that we think may be relevant to you. We also share personal information with our consultants and advisers (e.g., outside counsel, tax advisers). Corporate Restructuring. If we (or our assets) are acquired by another legal entity, whether by merger, acquisition, bankruptcy or otherwise, that legal entity would receive all information gathered by the Company via the Services, including your personal information retained thereon. To the extent practicable, we will notify you of any such change in corporate ownership by posting a notice on the Sites or taking similar actions. Compelled Disclosure. We will use or disclose your personal information if required by law, statute, or regulation, or judicial or administrative order or decree, or any other demand submitted by a government, regulatory, or judicial entity that has the force and effect of law. Business Interests. We reserve the right to use and disclose your personal information to a third party if we reasonably believe that use or disclosure will protect our rights or your safety or the safety of others. Privacy Policy. This Privacy Policy may describe other circumstances in which the Company shares personal information with third parties, and such descriptions shall not limit the categories of sharing set forth in this Section of the Privacy Policy and the personal information descriptions set forth in this Section shall not limit the Company's ability to share personal information as set forth elsewhere in this Privacy Policy. 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 consent to the same. 7. THIRD-PARTY LINKS, SINGLE SIGN ON (SSO) The Company may include on our Services certain links to other websites, including websites operated by unaffiliated third parties. Each such third-party website has its own privacy policies and practices, which may be different than the policies and practices described herein; we urge you to read any privacy policy posted on a third-party website carefully as such third party privacy policy (and not this Privacy Policy) controls with respect to the collection, use, and processing of your personal information thereon. Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that the Company exercises no authority or control over that third party and we cannot be, and are not, responsible for any information that you may submit at that website or how it is used. You may log into our Services through or from a third party social media or authentication service. These sign-on services will authenticate your identity, provide you with the option to share certain personal information (e.g., name, email address, profile picture, location) with us, and pre-populate our forms or other parts of our Services with the personal information already retained by the third party. You should verify your privacy settings on these third party services to understand and determine the types of personal information sent to us. Social Media. We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media's direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Sites include social media features and widgets (e.g., the "Facebook Like" button, the "Share This" button) or interactive mini-programs that run on the Sites. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Sites. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them. According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform ("Platform Data") be deleted or modified. If you would like Platform Data related to you deleted or modified, please contacts us in accordance with the "Contact Us" section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform. 8. THIRD-PARTY COLLECTION AND TRACKING When you access the Services, certain third parties may use automatic information collection technologies to collect information about you or your device that is used to access the Services. These third parties may include advertisers, ad networks, and ad servers; analytics companies; your mobile device manufacturer, and your mobile service provider. They may collect personal information about your online activities over time and across different websites, apps, and other websites. They may use this information to provide you with interestbased (behavioral) advertising or other targeted content. We do not control the tracking technologies employed by third parties or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. See Technical Data (above) for more information. 9. DATA RETENTION AND LOCALIZATION The time period in which the Company retains your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with products and services, to facilitate transactions you have requested, or to engage in marketing activities, and for so long as necessary to comply with applicable laws and regulations (including tax law) and defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy. The Company is based in the United States and the personal information that we collect and process is retained and stored in the United States. Please be aware that the United States may not provide the same level of protection of personal information as in your country, state, or jurisdiction of residence or nationality, and when transferred to the United States, your personal information may be accessible by, or otherwise made available to, government authorities and officials pursuant to regulatory, judicial, and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations, applicable in the United States. You hereby consent to your personal information being transferred to, and stored in, the United States. 10. INFORMATION SECURITY 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 SERVICES 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 INCIDENT THAT COMPROMISES OR MAY COMPROMISE THE CONFIDENTIALITY, SECURITY, INTEGRITY, OR AVAILABILITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY AND YOU HEREBY RELEASE US FROM ALL CLAIMS ARISING FROM THE SAME. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access the Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our Services have been compromised. 11. NO PERSONAL INFORMATION COLLECTED FROM CHILDREN Our Services are not directed at, nor intended for use by, children under the age of sixteen. As a result, we will not knowingly collect information from children under sixteen years of age with or without consent from their parents or guardians. If you are under the age of sixteen, you are hereby prohibited from using our Services or with providing us with your personal information. If you are a customer who provides us with general information about children, you hereby represent and warrant that you have the right and authority to provide us with such data. 12. YOUR RESPONSIBILITIES AND WARRANTIES You are permitted, and hereby agree, to only provide personal information to the Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon any individual's data privacy rights or privileges. IF YOU PROVIDE THE COMPANY WITH ANY PERSONAL INFORMATION ABOUT YOURSELF OR A THIRD PARTY, YOU EXPRESSLY REPRESENT AND WARRANT TO THE COMPANY THAT (I) YOU HAVE THE FULL RIGHT AND AUTHORITY TO DISCLOSE SUCH PERSONAL INFORMATION TO THE COMPANY, (II) THE COMPANY CAN USE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, AND (III) YOU ARE IN COMPLIANCE WITH THE REQUIREMENTS SET FORTH HEREIN. YOU ALSO AGREE TO FULLY REIMBURSE THE COMPANY FOR ANY DAMAGES, LOSSES, OR EXPENSES THAT ARISE BASED ON YOUR VIOLATION OF YOUR REPRESENTATIONS, WARRANTIES AND RESPONSIBILITIES SET FORTH IN THIS PRIVACY POLICY. 13. COOKIES We use different analytic tools which serve the purpose of measuring, analyzing and optimizing the performance of our Sites, marketing purposes, and, for providing you with customized advertisements that could be of particular interest to you. For information, see our Cookie Policy. 14. EMAIL MARKETING You have the right to opt-out of receiving electronic direct marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to "unsubscribe" from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the "Contact Us" section listed below. You hereby agree to immediately notify Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us. 15. CALIFORNIA PRIVACY RIGHTS Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 ("CCPA"), California residents are entitled to certain data privacy rights: • Right to Know (Specific Pieces of Personal Information). You have the right to know the specific pieces of your personal information that we have collected about you. • Right to Know (Categories of Personal Information). You have the right to know (i) the categories of personal information we have collected from you; (ii) the categories of sources from which the personal information is collected; (iii) the categories of your personal information we have sold or disclosed for a business purpose; (iv) the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and (v) the business or commercial purpose for collecting or selling your personal information. • Right to Delete. You have the right to request that we delete your personal information that we have collected and retain. • Right to Correct. You have the right to request that we correct inaccurate personal information that we have collected and retain. • Nondiscrimination. You have the right not to be subject to discrimination for asserting your rights under the CCPA. Submit a Privacy Request. To submit a privacy request, you (or your authorized agent) may contact us using the "Contact Us" section below. An authorized agent must be registered with the California Secretary of State to conduct business in California. Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information, Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email, request certain contact information or government identifiers, and we will match at least two pieces of such personal information with data that we have previously collected from you before granting you access to, erasing, or correcting, 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, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA's rights are absolute, and such rights are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see https://oag.ca.gov/privacy/ccpa. Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the "sale" of their personal information. However, Company does not sell your personal information to third parties for profit or monetary or other valuable consideration, and therefore we do not provide optout request processes for the sale of personal information (because we do not undertake such activities). Opt-Out Rights / Do Not Share My Personal Information. California residents have the right to opt out of the "sharing" of their personal information. Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve the disclosure of your personal information to third parties and may constitute the "sharing" of your personal information for CCPA purposes. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a "Your Privacy Choices" or a "Do Not Sell/Share My Personal Information" link) on the footer of the Site to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the "Contact Us" section listed below. Children. The Site is not directed at, and should not be used by, minors under the age of sixteen (16), and therefore Company does not knowingly sell or share the personal information of minors under sixteen (16) years of age. Limit Use of Sensitive Personal Information. Company does not use or disclose sensitive personal information for reasons other than those set forth in the CCPA, and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive personal information. California "Shine the Light". Under California Civil Code Section 1798.83 ("Shine the Light"), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes; and (b) the names and addresses of all such third parties; however, we do not disclose personal data to third parties for their direct marketing purposes. 16. COLORADO PRIVACY RIGHTS Data Privacy Rights. Pursuant to the Colorado Privacy Act (CPA), Colorado residents are entitled to the following data privacy rights: • To confirm whether or not we are processing your personal information and access such personal information, unless such confirmation or access would require us to reveal a trade secret. • To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information. • To delete personal information provided by, or obtained about, you. • To obtain a copy of your personal information processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Submit a Privacy Request. To submit a CPA privacy request, please contact us in accordance with the "Contact Us "section below. If you would prefer, you may designate an authorized agent to submit a CPA privacy request on your behalf. Privacy Request Verification Process. If you make any request related to your personal information, Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, Company will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Colorado Privacy Act, please see https://coag.gov/resources/colorado-privacy-act/. Privacy Requests Appeals Process. If you would like to appeal a decision Company has made with respect to your privacy request, please email us in accordance with the "Contact Us" section listed below, with the subject line "ATTN: Privacy Appeals," and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Colorado Attorney General at: https://coag.gov/file-complaint/. Opt-Out Rights / The Sale of Personal Information. Colorado residents have the right to opt out of the "sale" of their personal information. However, Company does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide optout request processes for the sale of personal information (because we do not undertake such activities). Opt-Out Rights / Targeted Advertising. Colorado residents have the right to opt out of having their personal information used for targeted advertising purposes. Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a "Your Privacy Choices" or a "Do Not Sell/Share My Personal Information" link) on the footer of the Site to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the "Contact Us" section listed below. Opt-Out Rights / Profiling. Colorado residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, Company does not engage in such activities. 17. CONNECTICUT PRIVACY RIGHTS Data Privacy Rights. Pursuant to the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, also known as the Connecticut Data Privacy Act (CDPA), Connecticut residents are entitled to the following data privacy rights: • To confirm whether or not we are processing your personal information and access such personal information, unless such confirmation or access would require us to reveal a trade secret. • To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information. • To delete personal information provided by, or obtained about, you. • To obtain a copy of your personal information processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means, provided we shall not be required to reveal any trade secret. Submit a Privacy Request. To submit a CDPA privacy request, please contact us in accordance with the "Contact Us" section below. If you would prefer, you may designate an authorized agent to submit a CDPA privacy request on your behalf. Privacy Request Verification Process. If you make any request related to your personal information, Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, Company will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Connecticut Data Privacy Act, please see https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy Act. Privacy Requests Appeals Process. If you would like to appeal a decision Company has made with respect to your privacy request, please email us in accordance with the "Contact Us" section listed below, with the subject line "ATTN: Privacy Appeals," and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Connecticut Attorney General at: https://portal.ct.gov/DCP/Complaint-Center/Consumers---Complaint-Center. Opt-Out Rights / The Sale of Personal Information. Connecticut residents have the right to opt out of the "sale" of their personal information. However, Company does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide optout request processes for the sale of personal information (because we do not undertake such activities). Opt-Out Rights / Targeted Advertising. Connecticut residents have the right to opt out of having their personal information used for targeted advertising purposes. Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a "Your Privacy Choices" or a "Do Not Sell/Share My Personal Information" link) on the footer of the Site to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the "Contact Us" section listed below. Opt-Out Rights / Profiling. Connecticut residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, Company does not engage in such activities. 18. NEVADA PRIVACY RIGHTS We do not currently conduct "sales" of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the "Contact Us" section listed below. 19. UTAH PRIVACY RIGHTS Data Privacy Rights. Pursuant to the Utah Consumer Privacy Act (UCPA), Utah residents are entitled to the following data privacy rights: • To confirm whether or not we are processing your personal information and to access such personal information, • To delete personal information provided by you to us, • To obtain a copy of your personal data that you previously provided to us in a format, that to the extent technically feasible is portable, to the extent practicable is readily usable, and allows you to transmit the data to another entity without impediment, where the processing is carried out by automated means. Submit a Privacy Request. To submit a UCPA privacy request, please contact us in accordance with the "Contact Us" section below. Privacy Request Verification Process. If you make any request related to your personal information, Company will ascertain your identity to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, or erasing, specific pieces or categories of personal information or otherwise responding to your request, Company will, to the extent required or permitted by law, (i) require you to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Utah Consumer Privacy Act, please see https://le.utah.gov/~2022/bills/static/SB0227.html. Opt-Out Rights / The Sale of Personal Information. Utah residents have the right to opt out of the "sale" of their personal information. However, Company does not sell your personal information to third parties for monetary consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities). Opt-Out Rights / Targeted Advertising. Utah residents have the right to opt out of having their personal information used for targeted advertising purposes. Company uses third-party analytical and targeted advertising features on our Sites and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a "Your Privacy Choices" or a "Do Not Sell/Share My Personal Information" link) on the footer of the Site to set your cookie preferences. You may also contact us in accordance with the "Contact Us" section listed below. 20. VIRGINIA PRIVACY RIGHTS Data Privacy Rights. Pursuant to the Virginia Consumer Data Protection Act, Virginia residents are entitled to certain data privacy rights: • To confirm whether or not the Company is processing your personal information, and to access such personal information. • To request the Company correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. • To request the Company delete your personal information. • To obtain a copy of the personal information that you previously provided the Company in a portable and, to the extent technically feasible, readily usable format that allows it to be transmitted to another entity without hindrance, where the processing is carried out by automated means. Submit a Privacy Request. To submit a privacy request, you may contact us using the "Contact Us" section below. Privacy Request Verification Process. If you make any request related to your personal information, Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, Company will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of Virginia's privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Virginia Consumer Data Protection Act, please see https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1. Privacy Requests Appeals Process. If you would like to appeal a decision Company has made with respect to your privacy request, please email us in accordance with the "Contact Us" section listed below, with the subject line "ATTN: Privacy Appeals," and describe the nature of your request, and the reason for requesting an appellate review. Virginia residents may file privacy complaints with the Virginia Attorney General (https://www.oag.state.va.us/contact-us/contact-info). Opt-Out Rights / The Sale of Personal Information. Virginia residents have the right to opt out of the "sale" of their personal information. However, Company does not sell your personal information to third parties for monetary consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities). Opt-Out Rights / Targeted Advertising. Virginia residents have the right to opt out of the "sharing" of their personal information for cross-contextual/targeted advertising purposes. Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a "Your Privacy Choices" or a "Do Not Sell/Share My Personal Information" link) on the footer of the Site to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the "Contact Us" section listed below. Opt-Out Rights / Profiling. Virginia residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, Company does not engage in such activities. 21. PERSONS WITH DISABILITIES The Company strives to ensure that every person has access to information related to our products and services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format and we will seek to meet your needs. 22. FINANCIAL INCENTIVE PROGRAMS We collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs ("Rewards Programs"). We use the personal information you provide in these programs to verify your identity, offer unique rewards, track your program status, and facilitate the exchange of program points for products, promotional materials, training workshops, and other items. If you consent to participate in any of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the "Contact Us" section listed below or in accordance with the instructions set forth in the applicable Rewards Program's terms and conditions. The Company may use personal information gathered from, or related to, participants in our Rewards Programs for any other purpose or in any other manner set forth in this Privacy Policy. California Rewards Program Rights. Pursuant to the CCPA, you 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 your personal information that forms the basis for offering the financial incentive or price or service difference, and (ii) a description of the method we used to calculate the value of your personal information. Generally, we do not assign monetary or other value to personal information. However, in the event we are required by law to assign such value in the context of Rewards Programs, or price or service differences, we have valued the personal information collected and used 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 (i) the categories of personal information collected (e.g., names, email addresses), (ii) the transferability of such personal information for us and our Rewards Programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our Rewards Programs, and (v) the product or service to which the Rewards Programs, or price or service differences, apply. The disclosure of the value described herein is not intended to waive, nor should it be interpreted as a waiver to, our 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. 23. DO NOT TRACK SIGNALS Some web browsers may transmit "Do Not Track" signals to our Services. 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, unless otherwise required by law, take action in response to these signals. 24. AGGREGATED DATA The Company collects and retains de-identified, and aggregated data relating to the use of our Services ("Aggregated Data"), and we use such Aggregated Data for our own business purposes, such as to analyze customers and to develop, improve, and market our services. For the avoidance of doubt, we may use Aggregated Data for any purpose and such Aggregated Data is not subject to this Privacy Policy. 25. COMMUNICATIONS DATA For the avoidance of doubt, in the event you provide the Company with a telephone number as part of your registration to the Services or as part of a purchase or transaction with us, you hereby consent and agree that the Company (or our service providers) may contact said telephone number by any means (including SMS/text message) for service and transactions purposes. 26. TALENT MANAGEMENT As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as contact information (e.g., name, title, residential address, telephone number, and personal email address); information in a curriculum vitae, resume, cover letter, or similar documentation (e.g., current and former employment/employer, level of education completed and schools attended, awards and recognitions, language proficiency, memberships and associations, references, publications, volunteer work, career goals, and, professional skills); details regarding the type of employment sought, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and, information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify the accuracy of your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We may also use this employment and application data for any other purpose set forth in this Privacy Policy. 27. CHANGES TO THE PRIVACY POLICY At any time, we reserve the right to add to, modify or remove portions of our Privacy Policy. The effective date of our Privacy Policy will be included at the beginning of the Privacy Policy ("Last Updated") and will serve as a notice of when changes have been implemented to the Privacy Policy. It is your responsibility to review this Privacy Policy to determine if any revisions have been made to it. Your continued use of our Services after any revisions have been made to this Privacy Policy will indicate your acknowledgement of such changes and agreement to be bound by the updated terms and conditions set forth herein. 28. CONTACT US If you have questions regarding this Privacy Policy, would like to request more information from us, or would like to exercise a data privacy right or privilege, please contact us at any of the following: (mail) Scrubin Uniforms, LLC, ATTN: Privacy Request, 6206 Benjamin Road, Suite 310, Tampa, FL, 33634; (interactive webform) https://support.scrubin.com/hc/enus/ requests/new; or (email) customerservice@scrubin.com.
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