- Information We Collect
We collect information about you in three ways: directly from your input, from third-party sources, and through automated technologies.
- Data You Provide to Us
The types of personal information that we collect directly from you depends on how you interact with us and the Service and may include:
- Contact details, such as your name and email addresses, postal address and phone number;
- Account login credentials, such as usernames and passwords, password hints and similar security information;
- Payment information, such as a credit or debit card number; (this will always be done by 3rd party so maybe we delete this??)
- Comments, feedback and other information you provide to us, including search query data and questions or information you send to customer support; and
- Interests and communication preferences, including preferred language.
- Data From Your Organization
We may obtain information about you from the organization with which you are employed or affiliated in order to fulfill your purchases, including:
- Your organization’s name, postal address, and phone number;
- Contact details, such as your name and work email address, postal address and phone number; and
- Other account registration information, such as job title
- Data From Other Sources
We also may obtain contact details and other information about you from our affiliates and from other third parties, including:
- Service providers that help us determine a location in order to customize certain products to your location;
- Partners with which we offer co-branded services or engage in joint marketing activities; and
- Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.
- Data From Service Use The Service may automatically collect information about how you and your device interact with the Service, including:
- Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data;
- Usage data, such as the features you used, the settings you selected, your URL click stream data, including date and time stamp and referring and exit pages, and pages you visited on the Service; and
- For location-aware Services, the region, city or town where your device is located in order to provide you with more relevant content for where you are in the world.
- Data You Provide to Us
- How We Use Your Information
Depending on how you interact with us and the Service, we use your personal information to:
- Provide, activate and manage your access to and use of the Service;
- Process and fulfill a request, order, download, or other transaction;
- Provide technical, product and other support and to help keep the Service working, safe and secure;
- Enhance and improve the Service and our other products and services and to develop new products, services and benefits;
- Offer you customized content and other personalization to make the Service more relevant to your interests and geography;
- Respond to your requests, inquiries, comments and concerns;
- Notify you about changes, updates and other announcements related to the Service and our other products and services; Deliver targeted advertisements, promotional messages, notices and other information related to the Service and your interests;
- Provide you with promotional messages and other information about products, events and services of ours, our affiliates and third parties such as sponsors;
- Invite you to participate in user testing and surveys as well as sweepstakes, competitions and similar promotions;
- Identify usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of our promotional campaigns and evaluating our business performance, or in other ways pursuant to a customer agreement; and
- Comply with our legal obligations, resolve disputes, and enforce our agreements
- Sharing of Your Information
- Your Organization
If you access the Service on behalf of your organization, your personal information and certain usage data gathered through the Service may be shared with persons authorized by your organization for the purposes of usage analysis and compliance, cost attribution and departmental budgeting.
- Our Group Companies and Service Providers
Depending on the Service provided, we share personal information with:
- Our affiliates, trading names and divisions within the Garland Industries group of companies worldwide (for a list, click here) and certain Garland Industries service companies that provide technology, customer service and other shared services functions; and (not sure if use GI or just keep them all separate??)
- Our service providers, suppliers, agents and representatives, including but not limited to, payment processors, customer support, email service providers, IT service providers, mailing houses and shipping agents;
- Your Choices
We share your personal information with our affiliates and with sponsors, joint venture partners and other third parties, including entities for which we are acting as an agent, licensee, application host or publisher, that wish to send you information about their products and services that may be of interest to you, as determined by your choices in managing your communications preferences and other settings. The Service may let you post and share personal information, comments, materials and other content. Any such contributions you disclose publicly may be collected and used by others, may be indexed by search engines, and might not be able to be removed. Please be careful when disclosing personal information in these public areas.
- For Legal Reasons
We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:
- meet any applicable law, regulation, legal process or other legal obligation;
- detect, investigate and help prevent security, fraud or technical issues; and/or
- protect the rights, property or safety of Garland Industries, our users, employees or others;
and as part of a corporate transaction, such as a transfer of assets or an acquisition by or merger with another company.
- Your Organization
- Your Communications Preferences
You can customize and manage your communications preferences and other settings when you register with the Service, by updating your account features and preferences, by using the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive, or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.
- Accessing and Updating Your Information
- Your Account
The Service may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is solely the responsibility of the user. Registered users may also close their account directly through the Service or by contacting the Service’s customer support.
- Your Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at OPTOUT@garlandind.com. (again separate or not? If separate then we need multiple addresses and multiple process) Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you use of our Services.
- Provide you a different level or quality of Services.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
You have the right under European and certain other privacy and data protection laws, as may be applicable, to request free of charge:
- access to and correction or deletion of your personal information;
- restriction of our processing of your personal information, or to object to our processing; and
- portability of your personal information.
If you wish to exercise any of these rights, please contact us. We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity. Access to personal information that Garland Industries gathers from public records and other sources to supply to organizations is subject to applicable laws and our consumer and data access policies.
- Your Account
- Data Retention
We retain your personal information for as long as necessary to provide the Service and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.
- Children’s Privacy
We do not knowingly collect information from children under the age of 13 or target the Service to children under 13.
- Data Security
We use a variety of administrative, physical and technical security measures to help safeguard your personal information.
- Locations of Processing
Your personal information may be stored and processed in your region or another country where Garland Industries affiliates and their service providers maintain servers and facilities, including [Australia, India, Ireland, the Philippines, the United Kingdom and the United States]. We take steps, including through contracts, intended to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law.
Where personal information is transferred from the European Economic Area (“EEA”) or Switzerland to a country that has not received an adequacy decision by the European Commission, we rely on appropriate safeguards, such as the European Commission-approved Standard Contractual Clauses and EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, to transfer the data.
- Grounds for Processing
When we collect from you any personal information within the scope of European data protection laws, we do so:
- where necessary to provide the Service, fulfill a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
- where necessary for our compliance with applicable law or other legal obligation;
- where necessary for the performance of a task carried out in the public interest;
- where applicable, with your consent; and
- as necessary to operate our business, protect the security of our systems, customers and users, detect or prevent fraud, enable our customers to comply with legal obligations, or fulfill our other legitimate interests as described in the “Information We Collect,” “How We Use Your Information” and “Sharing of Your Information” clauses above, except where our interests are overridden by your privacy rights.
Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.