Rev. October 7, 2022
- subscriptions to our newsletters and other marketing messages;
- invitations to and participation in our events;
- recruitment processes; and
- customer/contractor and potential customer/contractor matters.
1. PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
We collect personal information when you use our Services, create an account with us or submit personal information to us. Personal information means information relating to an identified or identifiable natural person such as your name, address, phone number or email address. The types of personal information that we may collect about you include, but are not limited to:
Information You Voluntarily Provide to Us on Our Services
The personal information we collect on or through our Site or services may include:
- information relating to the creation of an account on one of our websites or mobile applications, such as name, email address, postal address, telephone number and/or a unique individual password;
- information that you provide by filling in forms that we make available. This includes information provided at the time of creating an account on one of our websites or mobile applications, subscribing to or purchasing from our Site, posting material, or requesting information or assistance;
- your city, state and zip code for store locator purposes;
- information you provide when you report a problem with our Site or an online purchase or other transaction with us by email, our Site, telephone, in writing or through other means;
- voice recordings, and copies of your correspondence (including email addresses), if you contact us;
- information related to your participation in our programs;
- information you provide relating to your participation in a contest, sweepstake, promotion, or surveys that we may ask you to complete for research purposes; or
- payment card, transaction or financial account information, if you make a purchase.
Providing personal information this way is completely voluntary. If any form which collects your personal information allows you to voluntarily provide additional information, we seek this information because we think it will help us to give you a better-quality service. You do not have to provide such information if you do not wish to do so.
Information Collected Automatically
As you navigate through and interact with our Site or Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Site, including, but not limited to, traffic data, location data, logs and other communication data and the resources that you access and use on the Site.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, the website that referred you to our website, and the subject of the ads you click or scroll over.
Information You Provide to Our Affiliates and Subsidiaries
We may receive personal information about you from a company controlled by or under common control with IDEAL. We also may collect information about your use of the Services, such as your browser information, pages clicked, and time spent navigating the site. This information cannot be used to identify you. If we link this information with any personal information, we will treat such linked information as personal information.
Information Collected from Other Sources
We receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud.
- For instance, we may collect personal information about you from our business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference.
- Some information we collect is publicly available. For example, we may collect information you submit to a blog, a chat room, or a social network like Facebook, Twitter or Google+. We may also collect information about you from other companies and organizations. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product recommendations and special offers that are more likely to interest you.
We may use cameras, closed circuit television (CCTV”) to keep employees and customers safe and to look for ways to improve our customer experience. We do not use these cameras to identify people except when necessary for security reasons.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and Internet activities. We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Site or services, to make login to our Site or services easier (such as by remembering your User ID), to recognize you when you return to our Site, to track your interaction with the Site or services, to enhance your experience with the Site or services, to remember information you have already provided, to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Site or services. The length of time a cookie will stay on your browsing device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).
• Strictly Necessary Cookies. These cookies are essential because they enable you to use our Site. For example, strictly necessary cookies allow you to access secure areas on our Site. Without these cookies, some Site cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Site to work and they cannot be disabled.
• Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Site. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Site.
• Performance or Analytic Cookies. These cookies collect passive information about how you use our Site, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Site. We do not use these cookies to target you with online marketing. You can disable these cookies.
• Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.
We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.
Other Tracking Technologies
We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.
Pages of our Site and our emails 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 visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.
Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.
· First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
· Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.
- 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 of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://optout.aboutads.info/) or the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1). In addition, on your iPhone, iPad or Android mobile device, you can change your device settings to control whether you see online interest-based ads.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers, provide help pages relating to setting cookie preferences. Please visit your browsers help page for information related to preferences and cookies settings.
Do Not Track
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
If you do not want us to collect Location Information from your device, please delete our mobile application or disable your device’s location settings. Please note that disabling the location setting may affect certain features of the mobile application.
3. HOW WE USE YOUR INFORMATION
a) To Provide You Our Services
We will use your personal information to provide information or perform Services that you request. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing applicable Services. Your information may be available or provided to third-party service providers and contractors (such as the Site webmaster) that are contractually obligated to protect your information as disclosed in this Policy.
b) For Internal Use
We will use your personal information for the purposes of furthering our business, including analyzing your information and other uses. We may monitor how our users use our Site including without limitation search terms entered, pages visited, and documents viewed. This information may be stored with an IP address. This information is used solely for purposes of enabling us to provide you with a personalized Site experience. Aggregated forms of this data may also be used for research purposes in order to develop new products and identify future features and functions to develop for the Site.
c) To Provide You with Service-Related Communications
We will send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.
d) To Provide Customer Support or Respond to You
We collect any information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes or issues. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
e) To Enforce Compliance with Our Terms and Agreements or Policies
f) To Ensure the Security of the Services
We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
g) To Maintain Legal and Regulatory Compliance
Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.
h) To Engage in Marketing Activities
4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We may share personal information in the following circumstances:
a) Service Providers
c) Industry Partners or Sponsors
When you register or enter a promotion, sweepstakes, or contest through our Services, we may share the information you provide with authorized third-party providers (as described above in 4 a, participating sponsors, and advertising partners). Further, by entering any promotion, you are agreeing to the official rules that govern that promotion, which may require you to take certain actions, including, except where prohibited by law, allowing IDEAL and/or the sponsor(s) of the promotion to use the information in advertising or marketing associated with the promotion. Please review the relevant promotion, sweepstakes or contest rules for more information.
d) Corporation Transaction
Unless prohibited by applicable law, we may share, transfer or delete your personal information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by IDEAL or any affiliated company (in each case, whether in whole or in part). If required by applicable law, any such sharing of personal information will be reported to regulators in accordance with the applicable law.
e) Other Lawful Disclosures
5. THIRD-PARTY WEBSITES AND SERVICES
6. SECURITY PRECAUTIONS
We implement appropriate technical and organizational measures designed to ensure your personal information in protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. For example, we limit access of your personal information to authorized parties, periodically inspect, assess, and evaluate the effectiveness of our technical and organizational measures designed to ensure the security of our processing, and limit our collection and use of your personal information to the extent necessary to provide you with our services.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.
Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of personal information. Any transmission is at your own risk and we request that you use appropriate security measures to protect your personal information . If you believe that personal information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
7. RETENTION OF PERSONAL INFORMATION
We will keep your personal information or sensitive information for as long as necessary to fulfill the purposes we collected it for, including any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and all applicable legal requirements.
8. YOUR RIGHTS AND CHOICES
Correction: We must ensure that your personal information is accurate and up to date. Please advise us of any changes to your personal information by contact using the information in the “How To Contact Us” section below.
Rights of individuals in Australia: If you are located within Australia, you have the right to access personal information about you that we hold, and you may ask us to correct such personal information to ensure that it is accurate, up-to-date and complete. There is no charge to submit a request or to correct information, however we may apply an administrative charge for providing access to your personal information on request.
Please note that if you decide to exercise some of your rights, we may be unable to perform the actions necessary to achieve the purposes set out above or you may not be able to use or take full advantage of the services we offer.
Individuals located the European Economic Area, the United Kingdom or Switzerland (collectively “EEA”) at the time, please see Section 12, below for more information about your rights.
9. INTERNATIONAL TRANSFERS
While this is uncommon, when you access or use our Services, we may transfer your personal information to countries in the world where IDEAL conducts business. Such countries may be located outside of the country or jurisdiction where you are located and may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. In such countries, we will still handle your personal information in the manner describe herein. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.
Individuals located in the European Economic Area (“EEA”), the United Kingdom or Switzerland at the time they access our Services, please see Section 12, below.
10. CHILDREN’S PRIVACY
Our Services are not directed to or intended for use by minors. If we learn that we have received any personal information directly from a child under age 16, or such other age as set by the laws of jurisdictions where we operate without his or her parent’s verified consent, we will use that personal information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services and subsequently we will delete that personal information.
11. NOTICE TO CALIFORNIA RESIDENTS
This section applies to California residents, however, we will honor requests from individuals wishing to assert privacy rights, including access and deletion rights, to residents in other states in accordance with our policies. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary for the last twelve (12) months of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect the Personal Information, where we obtain the Personal Information, and the third parties that we may share the Personal Information.
We generally collect the following categories of Personal Information when you use our Services:
· identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
· commercial information such as records of products or services purchased, obtained, or considered by you;
· Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
· your geolocation, to the extent you have configured your device to permit us to collect such information;
· your geolocation, to the extent you have configured your device to permit us to collect such information;
· audio recordings of your voice to the extent you call us, as permitted under applicable law; and
· inferences about your preferences, characteristics, behavior and attitudes.
We generally do not collect “Sensitive Information”, as identified and defined by the CCPA (California Civil Code section 1798.140 (o)), or protected classifications about our users such as, social security numbers, driver’s license or state identification numbers, account numbers, credit or debit card, in combination with any required security code, access code, password or credentials that would permit access to an individual’s financial account, medical information, biometric information, professional or employment-related information, education-related information user name or email address in combination with a password or security question and answer that would permit access to an online account.
For more information about the Personal Information we collect and how we collect it, please refer to Sections 1 and 2, above.
We collect your Personal Information for the business purposes described in Section 3, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.
The categories of third parties with whom we may share your Personal Information are listed in Section 4, above.
If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information your account with us or the security of our network systems.
· Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, access, delete, or opt-out of sales.
· Right to Know. You have the right to request in writing a list of the categories of Personal Information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes. In addition, you have the right to request: (i) the categories of Personal Information we have collected about you, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual.
· Right to Access. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.
· Right to Delete. You have the right to request us delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.
· Right to Opt-Out of Selling. The CCPA broadly defines “Personal Information” and “selling” such that sharing identifiers and identifiers linked to you in exchange for money or other valuable benefit may be considered a sale. You have the right to opt-out of having your Personal Information sold. We do not sell your Personal Information.
To assert any of your rights above Information, please contact us by email at firstname.lastname@example.org or via phone at (800) 435-0705. To confirm your identity, we may ask you to verify Personal Information we already have on file for you. Verification is required for all access and Deletion requests. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
12. NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM AND SWITZERLAND
Our Relationship to You
• For personal information that IDEAL collects on or through its websites and mobile applications, the Entity that operates the website or mobile application is the data controller.
• For personal information that is collected in connection with our newsletters and other marketing message, the data controller is identified on the subscription form and in each subsequent marketing message you receive.
· For personal information collected in connection with invitations and participation in events, the data controller will be the Entity which is organizing such event as identified in the announcement for the event.
• For personal information collected in the context of a recruitment process, the data controller is the Entity identified in the job posting.
· For personal information that IDEAL collects pursuant to a customer or contractor relationship, the IDEAL Entity with which you have the customer or contractor relationship is the data controller.
· For activities in the context of the procurement of products and services, the data controller will be the Entity identified in the order form or agreement.
We will only contact individuals located in the EEA by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law or the individual’s consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your personal information in this way or to disclose your personal information to third parties for marketing purposes, please click an unsubscribe link in your emails or contact us at email@example.com. You can object to direct marketing at any time and free of charge.
Legal Bases for Processing Your Personal Information
Legal Bases for Processing: Based on our contract with you or to take steps at your request prior to entering into a contract.
• Section 3 a) To Provide You Our Services
• Section 3 b) For Internal Use
• Section 3 c) To Provide You with Service-Related Communications
• Section 3 d) To Provide Customer Support or Respond to You
• Section 3 e) To Enforce Compliance with Our Terms and Agreements or Policies
• Section 3 f) To Ensure the Security of the Services
• Section 4 a) Disclosure to Service Providers
Legal Bases for Processing: Based on your consent.
• Section 3 h) To Engage in Marketing Activities
• Section 4 c) To Industry Partners or Sponsors
• Section 4 b) To Affiliates
Legal Bases for Processing: Based on our legal obligations.
• Section 3 f) To Ensure the Security of the Services
• Section 3 g) To Maintain Legal and Regulatory Compliance
• Section 4 e) Other Lawful Disclosures
Legal Bases for Processing: To protect your vital interests.
• Section 4 d) Other Lawful Disclosures
Legal Bases for Processing: Based on our legitimate interests. When we process your personal data for our legitimate business interests we always ensure that we consider and balance any potential impact on you and your rights.
• Section 3 b) For Internal Use
• Section 3 c) To Provide You with Service-Related Communications
• Section 3 d) To Provide Customer Support or Respond to You
• Section 4 b) Disclosure to Our Affiliates Businesses
• Section 4 d) Disclosure Relating to Corporate Transactions
Your Individual Rights
We provide you with the rights described below when you use our Services. We may limit your individual rights requests in the following ways: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other's privacy; (c) to protect our rights and properties; and (d) where the request is frivolous or burdensome.
If you would like to exercise your rights under applicable law, please contact us at firstname.lastname@example.org. Please note, we may seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal information. When we fulfill your individual rights requests for correct (or rectification), erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort.
· Right of Access. Upon your request, we will provide you with a copy of your personal information in our files without undue delay and free of charge, unless we permitted by law to charge a fee.
· Right to Rectification (or “Correction”). You may request to correct or update any of your personal information in our files. We may provide you with the ability to update some or all of your personal information directly via the Services.
· Right to Erasure (or the “Right to be Forgotten”). Upon your request, we will erase any of your personal Information in our files that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object and there are no overriding legitimate grounds for our processing.
· Right to Data Portability. If we process your personal information based on a contract with you or based on your consent or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another controller, where technically feasible. personal information.
· Automated Individual Decision-Making, Including Profiling. While you do have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, under applicable law, we do not subject your personal information to such processing activities.
· Right to Object to and Right to Restrict Processing. Under certain situations, you may object to or seek to restrict our processing of your personal information.
International Transfers of Personal Information
We may store, process and transmit personal information in locations around the world, including locations outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.
We transfer your personal information subject to appropriate safeguards as permitted under the applicable data protection laws. Specifically, when your personal information is transferred out of the EEA, we have the required contractual provisions for transferring personal information in place with the third parties to which your information is transferred. For such transfers, we rely on legal transfer mechanisms such as Binding Corporate Rules, Standard Contractual Clauses, or we work under international agreements and treaties with respect to data privacy and cross border transfers of Personal Information, as may be applicable.
HOW TO CONTACT US