Privacy

We use personal information about you when providing our products and services, such as your identity and contact details, information about your relationship with us and any transaction and payment details.

In most cases, our contracts will be with the business that you represent, but we may hold this information about you personally if you are one of our contacts.

We use your information in this context in order to:

• Manage our customer accounts and relationships
• Provide you with information about your contract with us
• Provide you with information about our products
• Administer your orders, invoice and take payments
• Manage shipping, customs and logistics
• Handle customer refunds
• Verify your identity
• Deal with any complaints you may have
• Contact you about any changes that we make to our products

Legal Basis: If we have a contract with you personally, we need to use your information in these ways in order to perform our obligations under that contract. If our contract is with your business, we have a legitimate interest to use your information in this context in order to manage our customer relationships and contracts.

If you are (or represent) one of our suppliers, we use personal information about you in relation to your supply of products or services to us. This may include your identity and contact details, information about our relationship with you and any transaction and payment details.

In most cases, our contracts will be with the business that you represent, but we may hold this information about you personally if you are one of our contacts.

We use your information in this context in order to:

• Manage our supplier accounts and relationships
• Manage our procurement processes as well as shipping, customs and logistics
• Manage accounting and outgoing payments

Legal Basis: If we have a contract with you personally, we need to use your information in these ways in order to perform our obligations under that contract. If our contract is with your business, we have a legitimate interest to use your information in this context in order to manage our supplier relationships and contracts.

If you attend any of our events or training sessions, we may use personal information about you in the context of organising and hosting the event and its attendees.

This may include information about your identity and your contact details as well as information about your relationship with us (including any previous events you may have attended or your relationship with us as a customer or supplier).

Legal Basis: If we have a contract with you (for example if you have purchased a ticket to an event) then we need to use your information in this way to perform our side of that contract. Otherwise, we have a legitimate interest to use your information in this way in order to manage our events.

We may use your personal information to send you information about products or services that we think may be of interest to you. This may include your identity and contact details as well as information about your relationship or any past transactions with us.

If you choose to subscribe to our Newsletter, you consent to us using your personal information to send you news, updates and promotions.

If you are an individual using your own personal email address and you are not an existing customer, we will not use your personal information for direct marketing purposes unless you give consent, for example, by opting-in to receiving these communications when you submit a contact form on our website.

In other circumstances, we may not require your consent in order to send you information about our products or services – for example, if we contact you at your business email address, or if you are an existing customer.

You can withdraw your consent to receiving these types of communications at any time by unsubscribing, either by using the links in the emails we send to you or by contacting us to request this. If we do not rely on your consent, you may still unsubscribe from these communications in the same way.

Legal Basis: In some circumstances, we rely on your consent in order to use your personal information for direct marketing purposes. In other cases where we do not require your consent, we have a legitimate interest to use your information in this way as it helps us to promote our products and services.

We may use your personal information in order to manage and improve our business, products and services. For example, we may use your information in this context in order to:

• Review and improve our products and services
• Review and improve the performance of our systems (including IT and cybersecurity), processes and staff (including training and development)
• Monitor performance of customer and supplier accounts and generate internal reports and management information

We may use any of the personal information that we hold about you for these purposes, including your identity and contact details, information about your relationship with us and any transaction history, any correspondence or other engagements with you and information we collect online (for example through our website).

Legal Basis: We have a legitimate interest to use your personal information in this way as it helps us to improve our business and provide better products and services to our customers.

We may use your personal information in order to operate, maintain and improve our website and other online services. This may include information about your use of our website (including content you view, links you follow and the device and browser you use), your IP address and other identifiers, your general location and any login credentials.

We may use your information in this way in order to:

• Improve our website to ensure that content is presented in the most effective manner for you and for your device
• Monitor and improve our website performance
• Monitor the effectiveness of advertising or marketing campaigns
• Maintain the security and integrity of our website and online systems

Legal Basis: We have a legitimate interest to use your personal information in this way in order to effectively operate, maintain and improve our website and online services.

We use your personal information in order to correspond with you, whether by phone, email, post or online (for example through our website or social media accounts).

This may include your identity and contact details, as well as information about your relationship with us, any transaction history and any other personal information that you choose to provide to us.

Legal Basis: We have a legitimate interest to use your personal information in this way in order to communicate effectively with our customers, suppliers and other contacts.

We may use your personal information in other circumstances where it is reasonable to do so. For example, we may need to use your information in order to:

• Meet our legal obligations
• Detect or prevent fraud or other criminal activity
• Protect the vital interests of you or another person
• Handle an emergency situation
• Bring, defend or investigate legal claims

We will always use your data fairly and legally and, where we intend to use your data for any purpose that is not compatible with the purposes explained in this notice, we will contact you to explain this.

• Customer Relationship Management (CRM) platforms including HubSpot, Interlynx and Salesforce, to help us manage our customer and supplier relationships.
• Enterprise Resource Planning (ERP) software providers including Infor, to help us manage business resources and processes.
• Learning Management Systems including Brainier, for training and development.
• SurveyMonkey for customer and end-user feedback surveys.
• Customs brokers, freight forwarders, couriers and other service providers for managing logistics and shipping.
• Banks and payment service providers, to handle incoming and outgoing payments and the secure storage of sensitive financial details.
• Service providers of IT infrastructure and support, to help us effectively manage, maintain and troubleshoot our IT systems.
• Government Departments, where necessary for our legal, tax or other compliance obligations.
• Website developers and hosting providers and other cloud storage providers.
• Service providers of software platforms for administrative or productivity purposes.

The right of access allows you to obtain information about how we collect and use your personal data (including information about any disclosure, sharing or sale of your data), as well as copies of the information that we hold.

The right of rectification allows you to request that we update or correct information that we hold about you, if it is incorrect or outdated.

The right of erasure (also known as the “right to be forgotten”) allows you to request that we delete some or all of the information that we hold about you. This right is only available in certain circumstances, including where:

• we no longer need the data for the purpose it was collected for;
• we rely on your consent, and you withdraw that consent;
• you object to our use of your data (see “The right to object” below) and there are no overriding reasons for us to continue holding that data;
• we have used your data unlawfully; or
• there is a legal requirement to erase your data.

If you request erasure of your information in circumstances other than those above, we may not be able to comply with your request (for legal or administrative reasons).

You have the right to object to our use of your information:

• where we rely on our legitimate interests as our legal basis; or
• where we use your information for direct marketing purposes.

Please see “How we use your data” above for more information about the circumstances where we rely on a legitimate interest as our legal basis for using your information. If you object to our use of your information, we will stop that use unless there is a compelling, legitimate reason for us to continue.

If you object to our use of your information for direct marketing purposes, we will stop using your data in this way.

You have the right to request that we stop using your information (but still retain it) in the following circumstances:

• you tell us that the information is inaccurate (until we can verify its accuracy);
• we have used your information unlawfully (but you do not wish us to delete it);
• we no longer need the information for the purpose it was collected for, but we still need it in connection with a legal claim; or
• you have objected to our use of the data (see “The right to object” above), while we review your objection.

You have the right to request that we transfer your information (in a commonly used electronic format) to another organisation.

In any circumstances where we rely on your consent to use your information, you have the right to withdraw that consent at any time and for any reason. If you do, we will stop using your information in that context.

You have the right not to be subject to decisions made solely by automated means (e.g. by a software algorithm) which may produce significant effects for you.

We do not use automated decision-making to make any significant decisions about you. If you have any concerns or questions about this, please contact us.

If you are based in the UK or EU, you have the right to lodge a complaint with the national data protection supervisory authority. For example, in the UK, complaints may be submitted to the Information Commissioner’s Office (www.ico.org.uk/make-a-complaint).

This process may not be available to you if you are based outside the UK or EU, including in the US. However, if you wish to make a complaint about our use of your information, please contact us and we will handle it through our internal complaint procedures.

Under the California Privacy Rights Act you have the following rights in respect of your personal information. Please note that these rights are only legally available to California residents.

The right to know what personal information is sold or shared

You have the right to request information about:

• The categories of personal data we collect.
• The categories of personal data that we sell or share with third parties, and the corresponding categories of third party recipients.
• The categories of personal data that we disclose to third parties for specific business purposes, and the corresponding categories of third party recipients.

The right of no retaliation

You have the right not to be discriminated against or otherwise subject to any retaliation as a result of you exercising any of your rights under data protection and privacy laws. This means that we will not treat you any differently because you have exercised these rights.

We collect the following specified categories of personal information (as listed in CPRA §1798.140):

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
• Personal data as described in §1798.80(e) - any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
• Characteristics of protected classifications under California or federal law.
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
• Geolocation data.
• Audio, electronic, visual, thermal, olfactory, or similar information.
• Professional or employment-related information.
• Non-public education information.
• Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We also collect the following specified categories of sensitive personal information (as listed in CPRA §1798.140):

• Personal data that reveals your social security, driver’s license, state identification card, or passport number
• Personal data that reveals your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
• Personal data that reveals your precise geolocation
• Personal data that reveals your racial or ethnic origin, religious or philosophical beliefs, or union membership
• Personal data that reveals the contents of your mail, email, and text messages (except where we are the intended recipient of the communication)
• Information about your health
• Information about your sex life or sexual orientation

We may collect personal information about you for the following specified business purposes, as defined in the CPRA. Please see “How we use your data” above for more detailed information about how we use your personal information.

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use, including, but not limited to, non-personalized advertising.
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
• Providing advertising and marketing services, except for cross-context behavioural advertising.
• Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Under the CPRA:

• “Selling” personal information means a transaction whereby personal information is exchanged for monetary or other valuable consideration.
• “Sharing” personal information means disclosing or otherwise making personal information available to a third party for the purposes of for cross-context behavioural advertising.

We do not (nor have we done at any time since January 1, 2022) sell or share your personal information in these ways.