Last Updated: August 4, 2023
Description of Users and Acceptance of Terms
The Information We Collect and How We Use It
In the course of operating the Website, we collect or otherwise receive the following types of information:
We collect information collected on our Website varies depending on the webpage but typically includes some combination of your name, email address, contact type, company information (including address), and any information you provide in messages to us. We use such contact information for purposes such as responding to, and following up regarding, your inquiries, providing you with requested information, sending you email alerts (including marketing emails), or reviewing your job application materials. Depending on the nature of your message (e.g., purchase of products), we may route your information to an appropriate third party, such as a distributor, to better address such message.
Like most websites today, we use web servers that keep log files that record data each time a device accesses those servers. These log files are maintained by our website hosting service and contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Website, or the pages you’ve clicked on while on our Website). We may wish to use these log files for purposes such as monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.
We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your visit. We use both 1st and 3rd-party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.
- Session Cookies: We use session cookies to make it easier for you to navigate our Website. A session ID cookie expires when you close your browser.
- Persistent Cookies: A persistent cookie remains on your hard drive (or other storage medium) for an extended period of time or until you delete them. To the extent we provide a log-in portal or related feature on our Website, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Persistent cookies also enable us to track analytics and target the interests of our Visitors to personalize the experience on our Website.
In some cases, we may associate information that you have provided to us (e.g., email address) with the cookies that we use. In addition to facilitating the purposes described above, this is useful in understanding your engagement with other content related to our Website (e.g., email open rates, URL clickthroughs).
If you do not want us to place any cookies on your device (or any third-party cookies, if you’d like), you may be able to turn that feature off on your computer or mobile device. Please consult your browser’s documentation for information on how to do this. However, if you decide not to accept cookies from us, certain aspects of the Website may not function properly or as intended.
Third-Party Analytics Providers
As noted above, you may also set your browser to block all cookies, though this may disable other aspects of the Website.
In an ongoing effort to better understand our Visitors and the Website, we might analyze your information in aggregate form to carry out, maintain, manage, and improve operations in connection with the Website. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our services and the Website to current and prospective business partners and to other third parties for other lawful purposes.
Disclosure to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
We may process your personal information for other purposes as otherwise disclosed to you (or pursuant to your consent) during your experience on, or in relation to, our Website.
Sharing with Third Parties
Opt-Out for Email Marketing and Certain Other Communications
You may also manage your receipt of marketing communications by clicking on the "Unsubscribe" (or similar) link located on the bottom of an applicable marketing email and following the instructions found on any page to which the link may take you.
You may also manage your receipt of press releases and other communications (e.g., SEC filings) that you’ve signed up to receive via email by clicking on the link on the bottom of such applicable email communication and following the instructions found on any page to which the link may take you.
You cannot opt out of receiving administrative or transactional e-mails. In all such cases, please allow us a reasonable time to process your request.
How We Protect Your Information
We take commercially reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.
Retention of Personal Information
Important Notice to All Non-US Residents
Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. To the extent permitted under applicable law, your decision to provide such data to us, or allow us to collect such data through our Website, constitutes your consent to this data transfer.
Your California Privacy Rights
If you are a California resident, please click here regarding your rights and other information under the California Consumer Privacy Act (CCPA).
If you are located in the European Economic Area or United Kingdom, are otherwise afforded the protections of the General Data Protection Regulation (GDPR), please click here regarding your rights and other information under the GDPR.
Do Not Track
We do not respond to "Do Not Track" settings or other related mechanisms at this time.
Links to External Websites
How to Contact Us
CCPA Privacy Notice
Last Updated: August 4 2023
This CCPA Notice provides further detail regarding (a) how we have processed Consumers’ personal information within the past twelve (12) months and (b) your rights under the CCPA.
II. Personal Information We Collect
- Collection: We collect the categories of personal information listed below:
- Identifiers – Examples include name, email address, physical address, company name, and title.
- Commercial Information – Examples include products or services purchased, obtained, or considered and demographics/interests.
- Internet or Network Activity – Examples include page views, clickthroughs, referral and exiting URLs, time spent on pages, latency, and IP address.
- Geolocation (precise or generalized location of device)
- Professional or Employment Information – Examples include cover letter, and CV/Resume (including job experience, education).
- Characteristics of Protected Classifications under California or Federal Law – Examples include race, ancestry, gender, disability, sexual orientation, and military or veteran status.
Note that we may not collect each category of personal information above (or each example contained therein) in relation to every Consumer, depending on how Consumers interact with us through our Website.
- Sources: The above categories of personal information are collected from you directly or, in the context of Internet or Network Activity or Geolocation, from server logs or 1st/3rd-party cookies, pixels, or similar technologies.
- Business Purposes: We use the above categories of personal information for the following business purposes:
- Responding to inquiries and other messages
- Providing marketing materials and emails
- Audience measurement and analytics (e.g., understanding of how the Website is used, the locations where Consumers engage with the Website, engagement with social media and other marketing channels such as email, measuring clickthroughs from URLs)
- Providing location-specific services (e.g., finding a distributor, store, or event near you)
- Processing job applications
- Cybersecurity and fraud detection
- Compliance with applicable law
- Responding to lawful requests by public authorities
- Establishing, exercising, or defending legal claims
- Optimizing the Website and related services
- A merger, dissolution, reorganization, or similar corporate event, or the sale of all or substantially all of our assets (including, in each case, any due diligence relating thereto)
- Internal purposes aligned with Consumer expectations
- As otherwise either disclosed to you (e.g., via “just-in-time” notices) or pursuant to Consumer consent.
Note that each business purpose listed herein may not use every category of personal information described above. For example, “Protected Classifications” under California or Federal law are a designation primarily relevant to the employment context (and associated legal compliance). However, all information may be transferred in the context of a merger, sale, or similar event, as such are further described above.
- Disclosures: For the above business purposes, we disclose each of the categories of personal information above to third parties and service providers such as cloud storage and web hosting providers, distributors, technical assistance and security vendors, database management/back-up services, analytics services, email clients, digital marketing services (e.g., marketing automation), customer relationship management/CRM platforms, and customer service vendors. For clarity, we do not use professional or employment information or characteristics of protected classifications for marketing purposes.
III. Your CCPA Rights
- Access: You may request access to the personal information that we have collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months upon appropriate verification. You may only make such requests twice per every twelve (12) months.
- Deletion: You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations, as discussed below.
- “Do Not Sell” Requests: We do not “sell” your personal information, as such term is defined under the CCPA, nor do we have actual knowledge of any “sales” of personal information of minors under the age of sixteen (16).
- Exercising Your Rights: To exercise the access and deletion rights described above, please submit a request to us by either:
- Filling out this form: Personal Information Request
- Calling us at +1 888 340 2627
Consumers have a right to not receive discriminatory treatment for the exercise of their rights under the CCPA. Please note that a record of your requests, including how we responded and any correspondence or documentation related thereto, may be kept pursuant to our legal obligations.
IV. Verifying Your Rights Requests
Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verified before we can fulfill such request.
Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf (e.g., name, email address).
We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.
Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.
V. How to Contact Us
If you have any questions regarding our privacy practices as it relates to this CCPA Notice, please contact us via email at email@example.com with the subject line, “CCPA Notice.”
GDPR Privacy Notice
Last Updated: August 4 2023
Controller Disclosure & Details: We are a data controller of personal data regarding Visitors for the purposes and under the legal bases described in the table below.
Data Subject Category
Purpose & Legal Basis of Processing
Information Security: Our web servers will log Visitors’ IP address and other information (e.g., browser information, operating system, request date/time, user agent string, referral and exiting URL) in order to maintain an audit log of activities performed. We use this information pursuant to our legitimate interests in tracking Website usage, combating DDOS or other attacks, and removing or defending against malicious Visitors.
Email Communications: We will answer inquiries, such as those sent through a Contact Us (or similar) page, pursuant to our legitimate interest in answering such inquiries, ensuring prospective or Visitor satisfaction, and furthering business relationships.
We will send e-mail marketing communications to Visitors based on their consent. Visitors may also have the option to consent to other e-mail-based communications that are not marketing-related.
General Business Development: We have a legitimate interest in processing the personal data of Visitors to further business relationships and ensure Visitor satisfaction (e.g., by storing Business Contact information within a CRM or other file, answering inquiries per Email Communications above).
Applicant Processing: For “career” or similar pages, we have a legitimate interest in processing the personal data of Visitors that submit resumes, CVs, and similar materials for eligibility purposes.
Audience Analytics/Geolocation: We utilize web audience measurement tools such as Google Analytics pursuant to Visitors’ consent to understand how Site Visitors interact with our Website and optimize the Website and related services. Additionally, we may request consent for use of your geolocation in order to provide location-based services.
Compliance With Applicable Law: We will process Visitors’ personal data pursuant to (a) our obligations under member state or Union law or (b) our legitimate interests in complying with applicable law generally. This includes responding to lawful governmental requests and establishing, exercising, or defending legal claims.
Other: We may process Visitors’ personal data for other purposes as otherwise disclosed to you (e.g., via “just-in-time” notices).
Recipients: Our personnel process Visitors’ personal data for the purposes listed above. Such personal data is also disclosed to the following categories of recipients in relation thereto: Cloud storage and web hosting providers, distributors, technical assistance and security vendors, database management/back-up services, analytics services, email clients, digital marketing services (e.g., marketing automation), customer relationship management/CRM platforms, and customer service vendors. For clarity, we do not use job applicant information for marketing purposes.
Retention: We process Visitors’ personal data for as long as we have a legitimate business relationship with such Visitors or unless otherwise deleted upon request by such Visitors. Web server logs are deleted on a running 12-month basis.
Your GDPR Rights: You have a right to: (i) request access to, correction and/or erasure of your personal data; (ii) object to processing of your personal data; (iii) restrict processing of your personal data; and (iv) request a copy of your personal data, or have a copy thereof sent to another controller, in a structured, commonly used and machine readable format under the right of data portability. You may exercise these rights and submit a GDPR complaint by contacting firstname.lastname@example.org with the subject line “GDPR Notice.”
You also have the right to lodge a complaint about the processing of your personal data with an appropriate data protection authority, and, as applicable, to exercise third-party beneficiary rights under our Standard Contractual Clauses.
Contact details for the EU data protection authorities can be found at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Objecting to Legitimate Interest/Direct Marketing: You may object to personal data processed pursuant to our legitimate interest. In such case, we will no longer process your personal data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your personal data for direct marketing purposes by clicking “Unsubscribe” within a marketing email. In such case, your personal data will no longer be used for that purpose.
Transfer of Personal Data To Outside the EEA: Where otherwise not transferring personal data to an “adequate” country or organization (e.g., in the latter case, where an organization is certified under the Privacy Shield frameworks or, if invalidated, any similar mechanism replacing the Privacy Shield frameworks), we rely on Standard Contractual Clauses to ensure adequate protection for your personal data.
Governmental Access Requests: We may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Corporate Restructuring: In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal data as set forth in this GDPR Notice.
Updates to this GDPR Notice: If, in the future, we intend to process your personal data for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately within this GDPR Notice, and the “Last Updated” date at the top of this page will be updated accordingly.
How to Contact Us: Reach out to email@example.com with the subject line “GDPR Notice” for any questions, complaints, or requests regarding this GDPR Notice.