Version 1.1, valid from February 1, 2020.
This is the Data Protection Policy for Puratos Corporation (referred to herein as "Puratos", "we", "us", or "our"). This Data Protection Policy informs you of Puratos’ data and information privacy policies and practices. This Data Protection Policy explains the Personal Data we collect and receive about you, how we use and share your Personal Data, and your choices regarding our collection, use, and disclosure, both on this website and from certain offline sources, as described further below. This policy applies to the “Personal Data” that we process about you as a natural person. Personal Data means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This policy does not apply to: (a) anonymous information that cannot be associated with or linked to a particular consumer or household; or (b) business data.
Puratos is the ‘controller’ for the processing of your Personal Data. Puratos’ primary place of business is 1660 Suckle Highway, Pennsauken, NJ 08110. Puratos’ phone number is: (856)428-4300. Puratos’ email address is: firstname.lastname@example.org.
Puratos and its affiliated entities around the world are referred to herein as the “Puratos Group.”
Puratos and our third-party business partners and service providers (which are third-party companies that work on our behalf) collect information about you from a variety of sources, including information you provide directly to us (e.g., when you send us an email, sign-up to become a member of one of our programs, or purchase products from us), and information we automatically collect from you when you access and use our website, as further described below.
A. Personal Data You Provide Us When you utilize our website, purchase products, or contact us regarding our services and products, we collect the requested information that you provide in furtherance of these activities. The Personal Data that you provide may include, without limitation, the following categories:
• Identifiers (such as a real name, alias, date of birth, mailing address, mobile and home telephone and fax numbers, unique personal identifier, online identifier, account number, email address, account name, social security number, and driver's license information);
• Characteristics of protected classifications under California or federal law (such as your age, sex, credit, payment card and financial account information);
• Commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); and
• Professional or employment-related information.
You may choose whether or not to provide such Personal Data; however, the information may be required to utilize certain features of our website or to purchase products.
B. Personal Data Collected Automatically Puratos and our third-party business partners and service providers collect information automatically from you when you visit our website or otherwise use our online services, including in connection with our emails, online advertisements, and social media pages, as described in this section. As discussed further below, we and our business partners and service providers may use a variety of technologies to assist in collecting this information. Such information may include, without limitation, the following categories:
• Identifiers (such as a unique personal identifier, online identifier or IP address);
• Commercial information (such as products or services purchased, obtained, or considered, purchasing or consuming histories or tendencies, including, but not limited to, those related to your use of certain online services,); and
• Internet or other electronic network activity information, such as:
o Device Information. We may collect information about the devices (e.g., computer, tablet, and mobile phone) you use to access our online services, including your device model, IP address, operating system, the temporary or persistent unique device identifiers (sometimes called UDID), and mobile network operator information.
C. Personal Data We Receive from Third Parties Puratos may receive the Personal Data listed above about you from third parties, such as our business partners and service providers, including payment processors and marketing service providers.
We expect that you only communicate Personal Data about yourself to us. If you also communicate Personal Data about other people to us, then you must ensure that you are entitled to do so.
We also expect that the Personal Data that you communicate to us is correct and that, if specific data changes, you promptly inform us of this change.
The purposes for which we process your personal data depend on how you enter in contact with us.
You surf on our website
You contact us (e.g. by filling in a form on our website, by sending us an e-mail)
· We process your personal data in order to answer and manage your request (e.g. request for information, subscription to our newsletter, complaint). This processing is based on your consent.
You create a personal account on our website or purchase Puratos products/services
· We process your personal data for client management, based upon the performance of the contract to which you are a party. Without your personal data, we cannot perform this contract.
· We may also process your personal data for the direct marketing of our products/services, based upon our legitimate interests. We believe that it is important to keep you, as our client, informed about our products/services. This processing may involve compiling a profile. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience and personalized offers, which is an advantage for you. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below).
You subscribe to a Puratos activity
· We may process your personal data when you register for a Puratos activity (eg an event, a workshop or a webinar) because this is necessary for the performance of our agreement with you to organize this activity. We may do this in collaboration with commercial partners with whom we may share your data based on their legitimate interest in knowing who is registering.
· We may also use your personal data for direct marketing of our business based on our legitimate interests. We consider it important to keep you as our customer informed about our activities. This processing may consist of the creation of a profile. Creating a profile does not affect you, except that this processing can lead to an improved customer experience and tailored offers, which is an advantage for you. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below).
In any case
· We may process your personal data for the management of compliance and disputes (eg prevention of unlawful activities, prevention of abuse of the Puratos group’s resources, defense of legal claims).
· We may anonymize your personal data and process aggregate data for research and development, based on our legitimate interests (eg statistics about sales, market analysis, development of products/services). Within the Puratos group, we believe that research and development can lead to enhancement of customer experience, product improvement and innovation, which will help the persons concerned by our products/services (such as customers, distributors, suppliers and end consumers). The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below). Research and development may involve compiling a profile. All identifying elements, such as your name, your address, etc., are eliminated. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience, product improvement and innovation, which is an advantage for you.
· Puratos NV may also process your personal data as a controller, at a group level, for global management and global research, based on its legitimate interests, those of the other group entities and their stakeholders. We believe that this is necessary for the efficiency, consistency and continuity of the Puratos group operations and for the enhancement of customer experience, product improvement and innovation, which will help the persons concerned by our products/services and eventually contribute to safeguarding and promoting the economic, commercial, social and financial interests of the Puratos group. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below).
· We may process your personal data for the direct marketing of our products/services and of the products/services of other companies of the Puratos group, based upon your consent, to the extent that you give such consent.
We can transfer your personal data to companies that are a part of the Puratos group, to companies that process personal data in our name and on our behalf (known as ‘processors’), to scientific institutions in the context of research, to third parties when there is a legal obligation to do so, to our commercial partners (e.g. when organizing a joint activity), and to the police or judicial authorities at their request if they are entitled to request the personal data.
If your Personal Data is held or stored in the European Union, we can transfer your Personal Data to countries outside the European Union, including the United States. Each transfer will be based on appropriate safeguards (adequacy decision and/or standard data protection clauses of the European Commission). If you would like to know how to obtain a copy of the appropriate safeguards, you can contact us at the address stated above (article 2) or via email@example.com.
Your Personal Data is retained for as long as you are in contact with us (e.g. you ask information, purchase our products/services, subscribe to our newsletter) and for up to a maximum 10 years after the end of this relationship.
You can contact us to exercise the following rights, in accordance with the conditions laid down in the applicable laws and regulations:
• Withdrawing your consent for the processing of Personal Data, to the extent that the processing of your Personal Data was initially based upon your consent.
• Seeking access to, or any correction, deletion or restriction of your Personal Data.
• Objecting to any processing for direct marketing and/or any processing based on the legitimate interests as processing ground (such as research, development and improvement of our products/services).
• Seeking the portability of your Personal Data, which you have communicated to us.
You can exercise some of these rights via the settings in your personal account with us (if you have such a personal account).
You can exercise all of these rights by contacting us at the address stated above (article 2) or via firstname.lastname@example.org.
Depending on your residency, you may have certain additional data subject rights. These rights vary by state and country, but they include for California residents the right to: (i) request additional disclosures about the Personal Data we collect, use, and disclose, i.e., a "Request to Know (Categories of Information)"; (ii) obtain a copy of Personal Data, i.e., a "Request to Know (Specific Pieces of Information)," sometimes called the Right to Access; (iii) request deletion of Personal Data, i.e., a "Request to Delete Information," sometimes called the Right to Be Forgotten; and (iv) opt out of the sale of Personal Data if Puratos were to sell Personal Data, i.e., a "Request to Opt Out." Puratos does not sell your information, so you are already opted-out of such sales. Puratos will not discriminate against you for exercising any of these rights, for example, by charging a different price or denying goods or services. However, Puratos may charge a different price or rate or provide a different level or quality of goods or services when that difference is reasonably related to the value provided to us by the data.
You also have the right to file a complaint with the competent data protection authority.
If you wish to exercise your data subject rights please call us at (800) 654-0036 or email us at email@example.com. We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your Personal Data only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.
If you make a request related to Personal Data about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If it is necessary to collect additional information from you, Puratos will use the information only for verification purposes and will delete it as soon as practicable after complying the request. For requests related to particularly sensitive information, we may require additional proof of identification.
If you make a Data Subject Rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.
We will process your request within the time provided by applicable law.
In addition to the rights already described, under California law, California residents have the right to request certain details about how their information is shared with third parties and, in some cases, affiliates, for those third parties' and affiliates' own direct marketing purposes. Under the law, a business must either provide this information or permit California customers to opt in to, or opt out of, this type of sharing.
We may from time to time elect to share certain information about you collected by us in the course of providing the Services with third parties or affiliates for those third parties' or affiliates' own direct marketing purposes. If you are a California resident, you may request the above information or opt out of such future sharing of your personal information (as defined by the California Shine the Light Act) by contacting us at firstname.lastname@example.org or (800) 654-0036. We will respond to these requests within thirty (30) days. Requests that come by other means may result in a delayed response.