What Kind of Information We Collect
Whether accessing and using the Website from a personal computer, smartphone, tablet, or other Internet-enabled device (each a “Device” and collectively the “Devices”), we and our Affiliates (defined below) may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- “Identity Data” such as your first name, last name, marital status, title, date of birth and gender.
- “Contact Data” such as your billing address, delivery address, email address and telephone numbers.
- “Technical Data” such as internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
- “Usage Data” such as information about how you use the Website, our products, and our services.
- “Marketing and Communications Data” such as your preferences in receiving marketing from us and your communication preferences.
We do not collect any special categories of personal data about you, such as details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offenses.
We may collect Your Data directly from you when you provide it to us and or automatically as you use and navigate through the Website. To the extent we knowingly obtain certain legally protected information such as social security numbers, medical records/HIPAA protected information, or other similar information, whether such information is yours or that of a third party that was obtained from you, we will not use such information and destroy it immediately.
How We May Collect Your Data
We use different methods to collect Your Data including through:
- Direct interactions. You may give us Your Data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- subscribe to our service or publications;
- request for products and services information to be sent to you; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with the Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We will collect this Technical Data by using cookies, server logs, and other similar technologies described below.
- Third parties or publicly available sources. We may receive Your Data about you from various third parties such as:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment, and delivery services.
Purposes for Which We May Use Your Data
We will only use Your Data when the law allows us to. Generally, we will use Your Data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. “Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best services and products and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process Your Data for our legitimate interests. We do not use Your Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to comply with a legal obligation.
More specifically, we may use Your Data to:
- Process and manage your access to and use of the Website. The type of data collected includes Identity Data and Contact Data.
- Respond to your inquiries or requests. The type of data collected includes Identity Data, Profile Data, Contact Data, and Marketing and Communications Data.
- Create and deliver personalized promotions. The type of data collected includes Identity Data, Profile Data, Contact Data, and Marketing and Communications Data.
- Further business purposes, such as to perform data analysis, audits, fraud monitoring and prevention; to enhance, improve or modify the Website; to identify usage trends; to determine the effectiveness of our promotional campaigns; and to operate and expand our business activities. The type of data collected includes Identity Data, Contact Data, Technical Data, Usage Data, and Aggregate Data.
How We May Disclose Your Data
Your privacy is very important to us. We generally will not disclose Your Data to anyone, except in the following circumstances:
- Service Providers. We may disclose Your Data to third-party service providers who provide us with services such as website hosting, professional services, including information technology services and related infrastructure, customer service, email delivery, auditing and other similar services.
- To Perform Services You Request. We may disclose Your Data to third parties in order to perform services you request or functions you initiate.
- Corporate Transactions or Events. We may disclose Your Data to a third party in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, membership interests, or stock, including in connection with any bankruptcy or similar proceedings.
We have put in place appropriate security measures to prevent Your Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to Your Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process Your Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
What We Do Not Intend to Do With Your Data
We do not knowingly allow our third-party service providers to use Your Data for their own purposes and only permit them to process Your Data for specified purposes and in accordance with our instructions.
We, and many of our third-party service providers, control and operate our business and the Website from within the United States of America. Therefore, Your Data may be transferred out of your home country or region if you are not located within the United States of America. Once Your Data is received by us, we do not intend to and will now knowingly transfer Your Data outside of the United States of America, except as may be necessary to return it to you or to comply with applicable law. Our privacy practices are governed by the laws of the United States of America and the State of Ohio, which may differ from privacy laws in your state or home country or territory.
Choices About How We Use and Disclose Your Data
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over Your Data:
- Disclosure of Your Data for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by sending us an email stating your request to email@example.com.
- Promotional Offers from the Company. If you do not wish to have your email address/contact information used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to firstname.lastname@example.org. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to us as a result of a product purchase, warranty registration, product service experience or other transactions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to email@example.com.
How We Protect Your Data
We have implemented reasonable safeguards designed to prevent loss, misuse and unauthorized access, disclosure or modification of Your Data provided or collected through the Website. Your Data can never be 100% secure and you should always take appropriate security measures to protect Your Data. If you believe that any information you provided to us is no longer secure, please notify us immediately. Please be advised that when you post information in a public forum it becomes public information.
Technical Data and Cookies
Whenever you use a website, mobile application, or other internet service, certain information is created and retained by the website or application. This happens with the Website as well. We collect technical information that does not personally identify you when you use our Website, or information that has been made anonymous, such as Technical Data.
The technologies we use for automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or “Flash cookies”) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of the Website may contain small electronic files known as “web beacons” (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have the Website and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
If you do not wish to receive cookies or wish to manage cookies in general, you must configure your browser settings, if available, on your Device. Although you are not required to accept cookies, if you set your Device’s browser to reject cookies, you may not be able to use all of the features and functionality of the Website. If you block or otherwise reject cookies, you may lose some of the functionality of the Website.
Retaining and Deleting Your Data
We retain certain information, including transaction, location, device and usage information, for a minimum of seven (7) years in connection with regulatory, tax, insurance and other requirements. Once such information is no longer necessary to provide the Website, enable customer support, enhance the user experience or serve other operational purposes, we take steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.
You may request deletion of Your Data at any time by contacting us. Following such request, we delete the information that we are not required to retain. If we are unable to delete Your Data for any reason (for example, if there is an unresolved claim or dispute), we will delete Your Data once the issue is resolved.
Social Networking And Third Party Sites
Choice of Law, Jurisdiction
Special Information for European Union (“EU”) Users
Explanation and Copies of Your Data
- You have the right to request an explanation of the information that we have about you and how we use that information.
- You also have the right to receive a copy of the information that we collect about you if collected on the basis of consent or because we require the information to provide the Website or other services that you request.
Access and Correction
- You have the right to request access to Your Data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data of yours that we hold and to check that we are lawfully processing Your Data.
- If we have information about you that you believe is inaccurate, you have the right to request correction of Your Data.
Deletion and Erasure
- You have the right to be forgotten. This right is also known as the “right to erasure.” It is your right to have Your Data erased or the right to prevent processing in specific circumstances. Please see “Retaining and Deleting Your Data” above. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- You will not have to pay a fee to access Your Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
- You have the right of data portability. This right allows you to move, copy or transfer Your Data from one place to another in a secure manner without interrupting the integrity and usability of Your Data.
- You have the right to request restriction of processing of Your Data. This enables you to ask us to suspend the processing of Your Data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of Your Data is unlawful but you do not want us to erase it.
- Where you need us to hold Your Data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of Your Data but we need to verify whether we have overriding legitimate grounds to use it.
Objections and Complaints
- You have the right to object to our processing of personal data, including for marketing purposes based on profiling and/or automated decision making. We may continue to process Your Data notwithstanding the objection to the extent permitted under the GDPR.
- You may also have the right to file a complaint relating to our handling of Your Data with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority. Their contact information is as follows:
2509 AJ DEN HAAG
(+31) – (0)70 – 888 85 00
To exercise any of the above rights, please contact us. You may also submit questions, comments or complaints to our data privacy manager.
Use and Processing of Your Data
The GDPR requires that companies processing the personal data of EU users do so only with specific legal grounds. As described below, we process the information of EU users based on one or more of the grounds specified under the GDPR:
- To provide the websites and features you request. We must collect and use certain information in order to provide the Website to you. This includes usage information, which is necessary to maintain, optimize and enhance the Website.
- To protect the vital interests of our users or of others. We may process Your Data, including disclosure to law enforcement authorities, in case of threats to the safety of users or of others.
- For our legitimate interests. We collect and use Your Data to the extent necessary for our legitimate interests. Please see “Purposes for Which We May Use Your Data” above.
- For the legitimate interests of other persons or parties. We collect and use Your Data to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others. We may also process Your Data when necessary in regards to a substantial public interest, on the basis of applicable laws.
- To fulfill our legal obligations. We are subject to legal requirements in the jurisdictions in which we operate that may require us to collect, process, disclose and retain Your Data. For example, some record keeping laws may require us to keep Your Data for several years.
- We collect and use Your Data on the basis of your consent.
- You may revoke your consent at any time by contacting us at firstname.lastname@example.org.
- If you revoke your consent, you will not be able to use the Website or any feature that requires collection or use of the information we collected or used on the basis of consent.
- We rely on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you.
- You have the right to withdraw previously provided consent for our processing of Your Data.
Payment of all filing, administration and arbitrator fees will be governed by the AAA’s rules. If the arbitrator determines the claim(s) you assert in the arbitration are frivolous, you agree to reimburse us for all fees and expenses associated with the arbitration that we have paid.
Under California Civil Code sections 1798.83-.84, California residents who have established a business relationship with us may request from us a notice describing what categories of personal information we share with third parties or affiliates for those third-parties or corporate affiliates’ direct marketing purposes. Such notice will identify the categories of information that we shared and will include a list of the third parties and affiliates with whom the information was shared, including their names and addresses. If you are a California resident and would like a copy of this notice, you must submit a written request to us. We will respond within 30-60 days.
Children’s Online Privacy
We strongly believe in the importance of protecting the privacy of children. We will not knowingly collect any personally identifiable information from children under eighteen (18) years of age. When you disclose Your Data to us, you are representing to us that you are at least eighteen (18) years of age. If a child under eighteen (18) years of age has provided us with personally identifiable information through the Website, we request that a parent or guardian email us at email@example.com and we will delete the child’s information from our records.
P.O. Box 917
370 Gateway Dr.
Chillicothe, Ohio 45601
Our routine communications regarding the Website and legal notices will be posted on the Website. Notices are deemed received as of the time posted or delivered, or if that time does not fall within a Business Day, as of the beginning of the first Business Day following the time posted or delivered. For purposes of counting days for notice periods, the Business Day on which the notice is deemed received counts as the first day. Notices must be given in the English language. “Business Day” means any day other than Saturday, Sunday, and U.S. Federal holidays.
Reservation of Rights
All rights not expressly granted herein are reserved by us.