When we use the terms “Davis-Standard”, “we”, “us”, or “our” in this Policy, we are referring to Davis-Standard, LLC and our affiliates. When we use the term “Service” or “Services”, we are referring to all of our services and product offerings, our websites and their sub-sites, and any other website that posts or links to this Policy.
For purposes of applicable data protection laws, the “Data Controller” (or similar term under applicable law) is Davis-Standard, LLC, 1 Extrusion Drive, Pawcatuck, CT 06379 USA and is generally responsible for and controls the processing of your personal information collected through your use of our Services.
This Policy applies globally. Please refer below for additional disclosures that may be applicable to you:
- United States: If you are a resident of the United States, please see ADDITIONAL NOTICE FOR U.S. RESIDENTSsection below for additional state-specific privacy information.
- Europe:If you are living or located in the European Economic Area (“EEA”) which includes the European Union (“EU”), the United Kingdom (“UK”) or Switzerland, please see the ADDITIONAL NOTICE FOR EUROPEAN RESIDENTS section below for additional European-specific privacy information.
When you use our Services, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services and sometimes we collect personal information directly from you. At times, we may collect personal information about you from third parties.
Personal Information You Provide
We may collect the following personal information from you:
- AccountData. We may collect the name of your business, your first and last name, your contact information, additional business information, and payment information. We also collect information on products and services you are interested in or may want to receive from us.
- Financial Information.Where permitted by law, we may collect financial information that may be considered personal information under applicable law. We may also use third party credit bureau data about you where available and permitted by applicable law.
- Contractual Information. If you order any Services from us, we will collect the name of your business, your contact information, additional business information, payment information and financial information.
- Contact Information. When you contact us, we may collect information from you regarding the subject of your inquiry, area of interest, project type, company, contact information, and contents of your inquiry. Depending on the method of contacting us, we may automatically collect certain additional technical information, such as the time the communication was sent, device specifications and IP address.
- Feedback and opinions.When you contact us directly or via our agents, we may record your comments and opinions.
- If you decide to submit a comment on our website or one of our blog posts or news articles, we may collect your name and contact information.
- Newsletter, Marketing Emails, and Blog. If you sign up to receive news or alerts from us, we may collect your name and contact information. We also collect certain website tracking information.
- EmploymentIf you apply for employment via our websites, we collect relevant information, such as contact information, Resume/CV, and any other information you choose to provide.
Personal Information Automatically Collected
We and our third party providers and partners collect certain personal information automatically when you visit, interact with, or use our Services:
- Use of our websites or interaction with our emails. We may collect your log data. Such data includes yourIP address, operating system, browser details, unique identifiers, device type and version, the referring URL, date/time of your visit, the time you spent on our Services and any errors that may occur while using our Services.
- Web Analytics.In addition to the technical data above, we collect certain analytical data, such as which products and services searched, type of usage, and certain actions that help us understand the way you use our Services.
- Remote Access Tools. If you engage in a remote access session with our support, we will collect certain technical information, such as your IP address, time and date of the access, and we will see all data that is visible on your screen at some point during this session.
- Security information (such as captcha). We automatically collect certain information that we need to secure our Services, such as yourIP address, operating system, browser details such as type, ID, configuration, unique identifiers, device type and version, the referring URL, date/time of your visit, and the time you spent engaging with our Services.
Personal Information from Other Sources and Third Parties
We may also obtain personal information from third parties, which we may combine with personal information we collect either automatically or directly from an individual.
We may receive personal information from the following third parties:
- Davis-Standard Affiliates.We may receive personal information from other companies owned or controlled by or under common control with Davis-Standard.
- Partner Entities. If our business partners collaborate with us, they may disclose your name, contact information, opportunity/interest details of your company, information about outstanding payments, and whether you or your company is a current customer of our partner.
- SocialMedia. When you interact with us through various social media networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
- ServiceProviders. Our service providers that perform services on our behalf collect personal information and often share some or all of this information with us.
- Your Employer.If you work for one of our customers, we may receive certain personal information about you from them to enable you to purchase and use our Services. Such personal information may include your name, title, and contact information.
We may use the personal information we collect for the following purposes:
- Fulfilling our contractual obligations, to deliver the Services you have requested, and for account and contract management (including customer support);
- Communicating with individuals, including via email, text message, social media and/or telephone and video calls;
- Reviews ofour business performance;
- Marketing our Services to businesses and individuals, including through email, direct mail, phone, or text message;
- Administering, improving and personalizing our Services, including by recognizing an individual and remembering their information when they return to our Services;
- Processing payment for our Services;
- Conducting market research;
- Opportunity tracking, conversion and lead generation;
- Testing, enhancing, updating and monitoring the Services, or diagnosing or fixing technology problems;
- Helping maintain the safety, security and integrity of our property and Services, technology assets and business;
- Enforcing our contractual rights, including without limitation, and to the extent applicable, the Davis-Standard Terms and Conditions or other applicable terms.
- Resolving disputes, carrying out our obligations and enforcing our rights, and protecting our business interests and the interests and rights of third parties;
- Preventing, investigating or providing notice of fraud or unlawful or criminal activity; and
- Complying with legal obligations.
We may share personal information with third parties, as described below.
- ServiceProviders: We share personal information with third party contractors and service providers subject to reasonable confidentiality terms. The services provided on our behalf by such third-party contractors and service providers may include processing payments, providing web hosting and maintenance services, technology support providers, email communications providers, analytics providers, data storage providers, and web and video hosting providers and developers. Any such third-party contractors and service providers will be bound to process the data only on our behalf and under our instructions, unless such service providers act as their own data controllers.
- Davis-Standard Affiliates: We may share personal information with other companies and brands owned or controlled by Davis-Standard, and other companies owned by or under common ownership as Davis-Standard.Our Affiliates will use your personal information in the same way as we do in accordance with this Policy.
- Business and Marketing Partners: We may also disclose personal information to our business and marketing partners. We may obtain your consent where required by applicable law. Our business and marketing partners will use your information in accordance with their own privacy notices.
- Corporate Transactions: We may transfer any information we collect in the event we sell or transfer all or a portion of our business or assets. Should such a transaction occur, we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Policy.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors, law enforcement agencies, regulators, other authorities and other third parties for legal reasonsif we reasonably believe that such action is necessary:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal processes;
- to protect our rights and property and the rights, personal safety and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud or other criminal activity; or
- as otherwise required by applicable law.
- With Your Consent:We may disclose personal information about an individual with their consent or direction.
The amount of time Davis-Standard retains personal information varies, depending on the Services Davis-Standard has provided and the nature of the personal information held by Davis-Standard. We only retain personal information for such period of time as is necessary for the legitimate purposes for which the personal information is processed.
- CONTROL OVER YOUR INFORMATION
Email Communications. From time to time, we may send you emails regarding updates to our Services, notices about our organization, or information about Services we offer that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “Update Preferences” link provided at the bottom of the email and follow the instructions to unsubcribe. Please be aware that you cannot unsubscribe from certain services-related communications.
Applicable data protection law may grant you additional rights. Please see below for the region-specific disclosures applicable to you.
The Services may contain integrations or links to third party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party and not to Davis-Standard. Davis-Standard is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the privacy policies and online terms of those third parties to learn more about how they handle your personal information.
Our Services do not target and are not intended for children under the age of 16 and we do not knowingly collect personal information from children under 16.
- CHANGES TO THIS POLICY
We reserve the right to change this Policy from time to time in our sole discretion. We will notify you about material changes in the way we treat personal information by placing a prominent notice on the website, or through other appropriate communication channels. It is your responsibility to review this Policy periodically. All changes shall be effective from the date of publication unless stated otherwise.
If you have any questions or requests in connection with this Policy or other privacy-related matters, please send an email to email@example.com or contact us using the contact details set out in the DATA CONTROLLER section above.
These U.S. Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individuals in the United States under applicable state privacy laws.
COLLECTION AND USE OF PERSONAL INFORMATION
SALES OF PERSONAL INFORMATION AND SHARING FOR TARGETED ADVERTISING PURPOSES
The categories of third parties to whom we may share personal information for targeted advertising purposes include our affiliates, service providers, ad networks and advertising partners.
We may at times receive or process personal information to create de-identified data that can no longer be used to infer information about, or otherwise be linked to, a particular individual or household.
Where we maintain de-identified data, we will maintain and use the data in its de-identified form and not attempt to re-identify the data, except as required or permitted by law.
YOUR PRIVACY CHOICES
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
- The Right to Know.You have the right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you in the last 12 months, including:
- The categories of personal information collected;
- The categories of sources of the personal information;
- The purposes for which the personal information was collected;
- The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed;
- The categories of personal information shared for targeted advertising (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and
- The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.
- The Right to Access and Portability.You have the right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
- The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
- The Right to Correction.You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
- The Right to Opt Out of Sales or Sharing for Targeted Advertising.You have the right to direct us not to sell personal information we have collected about you to third parties for monetary or other valuable consideration, or share your personal information to third parties for the purpose of targeted advertising.
You may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights under applicable state law. However, the exercise of the rights described above may result in a different price, rate or quality level of Services where that difference is related to the impact the right has on our relationship or is otherwise permitted by law.
SUBMITTING PRIVACY RIGHTS REQUESTS
To submit a request to exercise one of the privacy rights identified above, please:
- Email firstname.lastname@example.org; or
- Call +1.860.599.6290.
We may need to verify your identity before processing your request and therefore may request additional personal information from you. We will only use personal information provided in connection with a rights request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above. For example, we may be unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
EXERCISE YOUR RIGHT TO OPT-OUT OF SALES OR SHARING OF PERSONAL INFORMATION FOR TARGETED ADVERTISING
Unless you have exercised your Right to Opt-Out, and as described in the Disclosure of Personal Information section of these U.S. Disclosures, we may share your personal information to third parties for targeted advertising purposes. The third parties with whom we share personal information in this manner may use such information for their own purposes in accordance with their own privacy policies.
You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
SUBMITTING AUTHORIZED AGENT REQUESTS
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf.
To verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
APPEALING PRIVACY RIGHTS DECISIONS
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request.
The following disclosures only apply to residents of the State of California.
- Personal Information Collection. In the last 12 months, we may have collected the following categories of personal information: identifiers, customer records, commercial information, internet/network information, geolocation data, professional/employment information and inferences generated from your use of our websites.
- Identifiers, such as your name, address, phone number, email address, government identification information, account information or other similar identifiers.
- Customer Records, such as credit card information, bank account information or other payment or financial information.
- Commercial Information, such as information about Services purchased or considered and your use of such Services.
- Internet/Network Information, such as device information, log, and analytics data.
- Sensory Information,such as audio recordings of phone calls between you and us, where permitted by law.
- Professional/Employment Information, including the business or organization you are associated with and, where applicable, your title with that business or organization and information relating to your role with the business or organization.
- Other Personal Information, including customer service and communication history, personal information an individual permits us to see when interacting with us through social media, personal information an individual provides us in relation to a question, request, inquiry, survey, or promotion, and messages you send us through our Services.
- Inferences, including information generated from your use of our Services.
- Disclosure of Personal Information. In the last 12 months, we may have disclosed the categories of information identified above to the following categories of third parties for business purposes include: our affiliates, service providers, business partners, and online ad networks and analytics providers. We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal processes or contractual obligations.
- Our Services do not target and are not intended for children under the age of 16 and we do not knowingly collect personal information from children under 16.
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable laws, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal information and you are authorized to submit the request on your child’s behalf (i.e., you are the child’s legal guardian or authorized representative).
- “Shine the Light”. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please email us at email@example.com.
- Notice of Financial Incentives.We may offer various programs, promotions and other financial incentives that may result in differences in our prices or services offered to consumers. To obtain access to these offerings, we may collect and retain personal information, such as name, contact information, professional information, and account information. We have determined that the value of these programs and other incentives are reasonably related to the value of the personal information we receive and otherwise process in connection with these programs and offerings. We estimate the value of the personal information we receive and otherwise process in connection with these programs and offerings by considering the expense we incur in collecting and processing the personal information, as well as the expenses related to facilitating the program or offering. The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer. Participating in any financial incentive program is optional.
If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Note we do not sell your personal information within the meaning of Chapter 603A. However, if you would still like to submit such a request, please contact us at firstname.lastname@example.org.
Davis-Standard maintains operations in Europe and may direct our Services to individuals located in the EEA, the UK, and Switzerland. In these instances, the following disclosures apply to our processing of personal data.
When we use the term “personal data” in this section, we mean information relating to an identified or identifiable natural person.
Regularly, we use your personal data based on the following legal grounds according to the Regulation (EU) 2016/679 (the “EU GDPR”) or, where applicable, the “UK GDPR” as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the UK European Union (Withdrawal) Act 2018 GDPR:
Performance of our contractual Services or prior to entering into a contract with you: If you order Services from us or if you contact us to request Information about our Services, we use your personal data to provide you with these Services, including for account and contract management, to facilitate user benefits and Services, including customer support, and process payment for our Services.
Justified by our legitimate interests: The usage of your personal data may also be necessary for our own business interests. We may use some of your personal data to market our Services to businesses and individuals; administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services or analyzing our customer-base; conduct market research; opportunity tracking, conversion and lead generation; test, enhance, update and monitor the Services, or diagnose or fix technology problems; help maintain the safety, security and integrity of our property and Services, technology assets and business; enforce our Terms and Conditions, resolve disputes, carry out our obligations and enforce our rights, protect our business interests and the interests and rights of third parties; and prevent, investigate or provide notice of fraud or unlawful or criminal activity.
Consent: In some cases, we may ask you to grant us separate consent to use your personal data. In this case, you can revoke your consent at any time.
Compliance with legal obligations. We are obligated to retain certain personal data because of legal requirements and we may be required by law enforcement to provide personal data on request.
We do not use your personal data for automated individual decision-making.
We will usually store the personal data we collect about you for no longer than necessary for the purposes as set out above, and in accordance with our legal obligations and legitimate business interests.
The criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:
- Contract. Where we are processing personal data based on contract, we generally will retain your personal data for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
- Legitimate Interests. Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account your fundamental interests and your rights and freedoms.
- Consent. Where we are processing personal data based on your consent, we generally will retain your personal data until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that personal data.
- Legal Obligation. Where we are processing personal data based on a legal obligation, we generally will retain your personal data for the period of time necessary to fulfil the legal obligation.
- Legal Claim.We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.
In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.
Security. We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored by our cloud-hosting provider or on secure servers. We will never send you unsolicited emails or contact you by phone requesting credit or debit card information.
International Transfers of Your Personal Data. The personal data we collect may be transferred to and stored in countries outside the EEA, UK and Switzerland in countries where we and our third-party service providers have operations. This includes the United States, where we are headquartered.
Where required under the GDPR, we will ensure that international transfers of your personal data are made pursuant to appropriate safeguards, such as:
- Ensuring that the personal data is only transferred to countries recognized as offering an equivalent level of protection as compared to the level of protection in the country you are located; or
- the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission or UK Secretary of State (as applicable) in connection with appropriate supplementary measures. The decision and the template text of these standard contractual clauses can be found here; or
- the transfer is made pursuant to appropriate safeguards, such as binding corporate rules.
If you wish to enquire further about these safeguards, including the specific contracts entered into, used, please send an email to email@example.com or contact us using the contact details set out in the DATA CONTROLLER section above.
OBLIGATION TO PROVIDE PERSONAL DATA
Some information, such as your name, address, payment information and information on your requested Services may be necessary for the performance of our contractual obligations. Without providing this information, you might not be able to request or use certain Services or enter into a contract with us. If information is required, we will let you know this is the case.
In accordance with applicable privacy law, you may have the following rights in respect of your personal data that we hold:
- Right ofaccess. You have the right to obtain certain information about our processing of your personal data which includes:
- confirmation of whether, and where, we are processing your personal data;
- information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your personal data; and
- in certain cases, a copy of thepersonal data we hold about you.
- Rightof portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
- Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay, such as if the continued processing of that personal data is not justified.
- Right torestriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data, such as where the accuracy of the personal data is contested by you.
- Right to withdraw consent. There are certain circumstances where we require your consent to process your personal data. In these instances, and if you have provided consent, you have the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
RIGHT TO OBJECT. You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason at any time.
You also have the right to lodge a complaint to your local data protection authority. If you are based in the EU, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner’s Office (https://ico.org.uk/global/contact-us/) or the Swiss Federal Data Protection and Information Commissioner https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html However, we encourage you to first contact us so that we can work together to solve any concerns you may have.
Due to the confidential nature of data processing, we may ask you to provide proof of identity when exercising the above rights.