PRIVACY, SECURITY, AND TRANSPARENCY
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FROM WHOM WE COLLECT PERSONAL INFORMATION
We may collect personal information from visitors to and users of our Website, customers, dealers, and third-party vendors and business partners.
Personal information generally means information that can be used to identify or be easily linked to you (for example, your name, address, telephone number, and email address). In some jurisdictions, the privacy laws include unique elements in what they consider to be the personal information of the consumers or data subjects they protect. If those laws apply to us, as in the case of the California Consumer Privacy Act (“CCPA”) or European General Data Protection Regulation (“GDPR”), our use of the phrase “personal information” includes the unique elements required by such laws.
The categories of information we collect from each of these groups, and the ways in which we use it, differs. It’s possible that the same person could fall into more than one group.
WHAT INFORMATION WE COLLECT
We obtain two types of information from you, store, and use: (i) non-personal information that’s collected automatically from each visitor, such as your device operating system; and (ii) personal information that you voluntarily provide to us or that is collected automatically.
By using our Website or completing any forms, or submitting any information to us, you signify that you agree with this section of our privacy statement and that we may use and disclose your information as described.
Voluntarily Submitted Information.
If you participate in certain activities via our Website, such as completing a dealer application or submitting a contact us form, you may be asked to provide us with information about yourself. The types of personal information we collect in those situations includes personally-identifying information (such as your name, email address, physical address, and phone number) and financial account information (such as your credit card information). We do not sell, rent, or trade voluntarily submitted personal information with third-parties.
If you don’t want us to collect this type of personal information, please don’t provide it. This means you shouldn’t participate in the activities on our Website that request or require it, and you may want to communicate with us by phone or regular mail instead. Participation is strictly your choice. Not participating may limit your ability to take full advantage of the Website, but it will not affect your ability to access certain information available to the general public on the Website.
Some of the ways you voluntarily give us your personal information and how we use it:
- Emails and Online Forms – When you send us an email or fill out an online form, such as on our contact us page, your email address and any other personal information (e.g., home address or phone number) that may be in the content of your message or attached to it, are retained by us and used to respond directly to you and to process your request. Depending on the personal information provided, communications from us may be in the form of emails, telephone calls, or text messages. We may also send you information about any of our products, services, or programs we think may be of interest to you.
- Registering for an Account– When you register for an account, you submit personal information to us such as your name and email address (or your child’s name and email address), which we then retain. We use that information to create and manage your account and, in some cases, establish a password and profile to communicate with you.
- Registering for Training and Other Programs –When you register for our Dealer training and other programs, you will be submitting the types of identifiers described above. We use this information to register you for the training or other program and send you communications regarding it.
Automatically Collected Information.
When you visit our Website, necessary information is passively collected through your web browser via the use of tracking technologies, such as a “cookie,” which is a small text file that is downloaded onto your computer or mobile device when you access the Website. It allows us to recognize your computer or mobile device and store some information about your preferences or past actions.
The necessary information we collect consists of the IP address from which you accessed our Website.
The non-necessary information we collect includes, but is not limited to: the domain name and IP address from which you accessed our Website; the type of browser and operating system you use; the date and time and length of your visit; the specific page visited, graphics viewed and any documents downloaded; the specific links to other sites you accessed from our Website; and the specific links from other sites you used to access our Website.
Additionally, if you access our Website from a phone or other mobile device, the mobile services provider may transmit to us uniquely identifiable mobile device information, which allows us to then collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone vendors also operate systems that pinpoint the physical location of devices, and we may receive this information as well if location services are enabled on your device. If you do not want us to collect and use geolocation data, disable location services on your device settings.
Regardless, we use both automatically collected information and mobile device information to compile generic reports about popular pages on our Website and see how visitors are accessing our Website. We then use that data to administer the Website and make them better, make your activities more convenient and efficient, and enhance the functionality of our Website, such as by remembering certain of your information in order to save you time.
We use and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described above in accordance with our internal data retention procedures.
User Beware: External Sites, Apps, Links, and Social Media.
We maintain a presence on one or more external social media platforms such as Twitter, Facebook, Instagram, YouTube, and LinkedIn. We may further allow features of our Website to connect with, or be viewable from, that external social media presence. Similarly, our Website may contain links to other websites or apps controlled by third-parties.
WHEN AND WITH WHOM WE SHARE PERSONAL INFORMATION
We use non-personal information to administer our Website, make it better, and make business decisions about what our customers might want.
We use voluntarily provided personal information for our legitimate interests, including to respond to your inquiries and provide you with the information, products, and services you have requested, amongst other uses, as further described below. We do not sell or rent your personal information to third-party data vendors or marketing companies. As you might expect, we disclose your information when required by law. We may use your personal information when we have your consent to do so, where required or permitted under applicable law.
In addition to those third-parties set forth above, we may share your information, including personal information, within our affiliates. Those companies will use such information in generally the same manner as we do under this privacy statement, which includes sending you information about their products, services, or initiatives that may be of interest to you.
Legally Compelled Disclosures.
We may disclose your information, including personal information, to government authorities and other third-parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including but not limited to responding to court orders and subpoenas.
To Prevent Harm.
We may disclose your information, including personal information, when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Website, or anyone else that could be harmed by such activities.
If a third-party acquires us or any of our affiliates, or substantially all of its or their assets, as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, your personal information may be one of the transferred assets.
Vendors and Business Partners.
We may share your information, including personal information, with our vendors and other third-parties with whom we have a contractual relationship. We do our best to disclose as little of your personal information as is needed by such parties.
We have adopted standards for those vendors and business partners who receive personal information from us. We attempt to bind such vendors and business partners to those standards via written contracts. We further attempt to contractually restrict what our vendors and business partners can do with the personal information we provide to them such that it is used only to the extent necessary to carry out the business purpose for which it was provided; is not disclosed to anyone else without our consent or under our instruction; remains, as between us and the applicable vendor or business partner, our property; and is not transferred out of the United States without our consent.
Please note, however, that we cannot guarantee that all of our vendors and business partners will agree to these contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply, and we are not liable for their actions or inactions of compliance.
YOUR RIGHTS AND OPTIONS
You do not have to provide personal information to enjoy most of the features of our Website. You may also opt-out of or unsubscribe to certain activities like newsletters and announcements. Residents of California and data subjects whose personal information was obtained while in the GDPR Jurisdictions have certain additional rights.
GDPR Jurisdictions means the countries composed of the European Economic Area, the United Kingdom (which soon will leave the European Union), Switzerland, and Japan, which, having received an “adequacy decision” from the European Commission, adheres to the material terms of the GDPR.
If we are using personal information you provided to us in order to enable us to send you materials, such as newsletters or product alerts via text or email, and you decide you don’t want to receive such materials, you may opt-out by following the opt-out instructions in the email or other communication (e.g., by responding to the text with “STOP”), or by contacting us using the contact information below. When we receive your request, we will take reasonable steps to remove your name from our distribution lists. It may take a period of time to remove your name from our lists after your request, and therefore, you may still receive materials for a period of time after you opt-out. In addition to opting-out, you have the ability to access, amend, and delete your personal information by contacting us using the contact information below.
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not specifically respond to browser “do not track” signals.
Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward and collect and use information from children under 13. We take those age-related requirements very seriously. We do not intend for our Website to be used by children under the age of 13 without first obtaining the verifiable consent of such child’s parent or legal guardian. Moreover, we do not knowingly collect personal information from minors under the age of 13. Only a parent or legal guardian may provide such information after adhering to our verification process for submitting such information via the Website. If we become aware that anyone under the age of 18 has submitted personal information to our Website, we will delete that information and will not use it for any purpose whatsoever. If you believe that someone under the age of 18 has submitted personal information to our Website, please contact us at email@example.com.
HOW WE PROTECT PERSONAL INFORMATION WE COLLECT
We take all reasonable security precautions to protect your personal information provided to our Website. We have adopted a security program that includes technical, organizational, administrative, and other security measures designed to protect, in a manner consistent with accepted industry standards and applicable law, against anticipated or actual threats to the security of personal information (the “Security Program”). We cannot, however, guarantee that your information, whether during transmission or while stored on our systems or otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction, or alteration will not occur. Except for our duty to maintain the Security Program under applicable law, we disclaim any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications, including personal information. We have every reason to believe our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks to the personal information we collect. We further periodically review and update our Security Program, including as required by applicable law.
Nonetheless, as part of our Security Program, we have specific incident response and management procedures that are activated whenever we become aware that your personal information was likely to have been compromised. We further require, as part of our vendor and business partner oversight procedures, that such parties notify us immediately if they have any reason to believe that an incident adversely affecting the personal information we provided to them has occurred.
THE CALIFORNIA CONSUMER PRIVACY ACT
When we collect personal information from California residents, we become subject to, and those residents have rights under, the California Consumer Privacy Act or “CCPA.” This section of our statement is used to allow us to fulfill our CCPA obligations and explain your CCPA rights. For purposes of this section, the words “you” and “your” mean only such California residents.
What do we collect from California Residents?
We collect the following categories of personal information: identifiers such as name, address, IP address, and other similar identifiers; personal information described in subdivision (e) of Section 1798.80 (California customer records statute) such as a name, address, telephone number, credit card number; commercial information such as products, services, or program purchased; internet/electronic activity such as browsing history and search history; geolocation data including geographic coordinates/physical location; and audio, video, electronic or other similar information. We have disclosed these categories of personal information for a business purpose within the last 12 months. We do not sell, and within the last 12 months, have not sold, personal information to third-parties.
Rights of California Residents
You have the following rights under the CCPA, in summary, the right to know about information collected, disclosed, or sold and the right to request deletion of your personal information. It’s important to us that you know that if you exercise these rights, we will not discriminate against you by treating you differently from other California residents who use our sites and mobile resources or purchase our services but do not exercise their rights.
You can exercise these rights up to two different times every 12 months. To do so, just contact us at firstname.lastname@example.org. We may ask you to fill out a request form. The CCPA only allows us to act on your request if we can verify your identity or your authority to make the request so you will also need to follow our instructions for identity verification.
If you make a verifiable request per the above, we will confirm our receipt and respond in the time frames prescribed by the CCPA.
THE EU GENERAL DATA PROTECTION REGULATION
We do collect or otherwise obtain personal information from data subjects located in the GDPR Jurisdictions. We fulfill our GDPR obligations with respect to our customers (and their own end-clients) and our vendors and business partners through a series of separate notices, contracts, or other terms provided to them at the time, and in the manner and form, GDPR and local law within each GDPR Jurisdiction requires.
We describe, in the immediately following section of this statement, how we comply with the GDPR for personal information collected from visitors to and users of our Website while they were in a GDPR Jurisdiction. Thus, for purposes of that section, the words “you” and “your” mean only such GDPR Jurisdiction-based visitors and users.
What do we collect from you in the GDPR Jurisdictions and how do we use it?
We collect from you the categories of personal information already described. The lawful basis on which we rely for such collection, later use and disclosure, is what the GDPR refers to as legitimate interest. of your personal information to third-parties, nor do we use it for automated decision making.
Cross-border Data Transfers and Third-party Processors
If we transfer personal information from the GDPR Jurisdictions to a location that has not been deemed by the European Commission to have adequate privacy protections, we do so in the manner the GDPR permits.
Rights of Data Subjects in the GDPR Jurisdictions
While we attempt to allow all visitors and users of our Website to exercise a degree of control over their personal information, under the GDPR, we have a legal obligation to do so for you. More specifically, with respect to personal information collected from you while you were in a GDPR Jurisdiction, you have these rights: transparency, access, correction and deletion, portability, who, what, why and where, and restriction or objection.
If you would like to exercise any of these rights, please contact email@example.com. Your ability to exercise these rights is subject to certain conditions and exemptions that you can read about in Articles 12 through 23 of the GDPR. Among those conditions is our right to decline part or all of a request if we cannot satisfy our reasonable doubts and concerns about your identity in a manner that helps us minimize the risk that unauthorized persons might use a GDPR right to access your personal information. We will respond to all requests without undue delay, and in accordance with the time frames, if any, prescribed by the GDPR. If you are not satisfied with how we use your personal information or respond to your requests, you have the right to complain to your data protection regulator. Contact information for the EU data protection regulators can be found here.
RIGHTS OF DATA SUBJECTS IN OTHER JURISDICTIONS
In other jurisdictions with similar data privacy regulations, we may collect from you the categories of personal information already described. We collect and manage (including disclose) such data in compliance with applicable local laws. As noted, we do not sell any of your personal information to third-parties, nor do we use it for automated decision making.
CHANGES TO THIS PRIVACY STATEMENT
The English language version of this privacy statement is the controlling version regardless of any translation you may attempt.
We reserve the right to change or update this statement from time to time. Please check our Website periodically for such changes since all information collected is subject to the statement in place at that time.
If you have questions about our privacy statement or privacy practices, please contact us at:
SAVI Controls, LLC
Attn: Legal & Compliance Department
2420 Tarpley Rd., Suite 205
Carrollton, Texas 75006