Last Updated on May 24, 2019
TABLE OF CONTENTS
- Personal information you voluntarily provide to us and Why?
- Information we automatically collect and Why?
- Information we collect from other sources.
- Information regarding social networking sites.
- How we use the information we collect.
- How we share the personal information we collect.
- International Transfers of Personal Information.
- Security and Protection of Information.
- Your choices.
- California Online Privacy Protection Act.
Data privacy is important to Infaco USA Inc., (“Infaco”, “we” or “us” or “our”).
Please note that for the purposes of the European Union’s General Data Protection Regulation (“GDPR”), Infaco is the data controller (“Data Controller”) of your Personal Information.
Infaco USA Inc.
2356 Research Drive
Livermore, California 94550
3.1 Personal Information voluntarily disclosed.
3.1.1 By Visitors.
When you visit our Website, you may voluntarily provide Personal Information to us. These are most commonly encountered when:
- you submit any query on our website;
- you register for newsletters or other communications from us;
- you communicate with us using interactive features on our Website (such as our “Contact Us” web form).
Personal Information you provide while visiting our Website, includes but it not limited to, your first and last name, e-mail address, address, city, state, zip code and country.
We use this Personal Information to communicate with you via email and better understand your needs. Occasionally we may use your Personal Information to contact you to complete surveys (that we use for marketing and quality assurance purposes), send you newsletters, offers, promotions, events and any other marketing information that we think may be of interest to you. However, please note that you will always be able to opt out of such communications at any time (see below).
3.1.2 By Customers.
When you use our Website or place an order for a Product online, you may voluntarily provide Personal Information to us relating to you and your use of our Website. These are most commonly encountered when:
- when you access or use the Website and place an order for a Product;
- you register for newsletters or other communications from us;
- you communicate with us using interactive features on our Website.
3.1.3 Transaction; Account Registration.
We collect and process your Personal Information when you place an order for a Product on our Website (a “Transaction”) with or without the creation of an account (“Account”). This Personal Information collected for a Transaction includes your first and last name, e-mail address, address, city, state, zip code and country, password and username if you create an Account.
We use this information to enable you to place an order on our Website and to process and fulfill your order.
3.1.4 Financial Information.
We use this information to process and complete your order and send you a Transaction email confirmation.
3.1.5 Additional Information.
You may also voluntarily disclose additional Personal Information when you contact our customer service for support or when you opt in for direct marketing emails. We use this information to communicate with you via email and better understand your needs. However, please note that you will always be able to opt out of such direct marketing communications at any time (see below).
4.1 Information collected through Tracking Technologies.
When you browse our Website, we may automatically collect certain information regarding your use of our Website (“Usage Information”).
Usage Information may include your internet protocol (IP) address, your browser type and operating system, device type, other unique identifiers (including mobile device identification numbers), Websites you visited before and after visiting our Website, pages you view and links you click on while using our Website, information collected through cookies and other tracking technologies, information about your interactions with e-mail messages, log files, and any other information about how you interacted with our Website.
We may collect this information to analyze your online activities on our Website and across third-party websites, to recognize you when you return on our Website, to store information about your preferences and to send you advertising and marketing emails. As provided below, you may opt out at any time of such advertising and marketing emails.
The technologies we use for Usage Information collection may include the following:
Strictly Necessary Cookies: Infaco may use some strictly necessary cookies necessary to enable you to use our Website and some of its features, such as the language you choose while visiting our Website, or to track your cookies consent. Because these cookies are necessary to deliver the Website, you cannot refuse them. You can always block or delete them by changing your browser settings. However, some of our features on our Website may not function properly if you disable such cookies.
Performance and Functionality cookies: Infaco may use performance and functionality cookies to collect information about how a Visitor, Customer or Professional may use our Website, for instance, which pages you visit most often, or if you get an error message from a web page, to monitor our Website performance, and improve our Site, Services and your experience. These cookies don’t collect personal information. However, without such cookies, certain functionalities of our Website may become unavailable.
Social Media Cookies. These cookies are used when you share information using a social media sharing button or “like” button on our Website or engage with us on or through a social networking website such as Facebook. The social network will record that you have done this.
Advertising and Retargeting Cookies. These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other Customers who have similar interests. Based on that information, and with our permission, third-party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third-party websites.
Managing Cookies. You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate op-out links. You can also change your browser settings on your computer or other device you’re using to access our Services. You can find all these opt-out links in the table below. If you have any questions regarding your cookie’s preferences, please direct any inquiry to email@example.com.
Type of Cookie Who serves them Purpose How to refuse Analytics
This cookie provides anonymized data to allow us to understand Customer behavior and marketing performance on our Website and Services.
Please click on the relevant opt-out link below: Social Media Cookie
This cookie is used when you share information using a social media sharing button or “like” button on our Website or you link your Account or engage with our content on or through a social networking site such as Facebook or Twitter. The social network will record that you have done this. This information may be linked to targeting/ advertising activities.
Please click on the relevant opt-out link below:
4.2 Do not Track (“DNT”) signals.
California law requires that operators of website and online services disclose how they respond to a Do Not Track signal and whether other third parties may collect personal information about an individual’s online activities from their Website or service. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a Customer visits, indicating that the Customer does not wish to be tracked. At this time, Infaco does not currently respond to Do Not Track signal. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.
We may also obtain information about you from other sources or retain third party services to operate our Website and help us monitor, collect, analyze and better understand your interactions with our Website. These other sources may include, without limitation, advertising services technologies and third-party advertisers, sponsor links on other third-party websites, database management, web analytics services.
Our Website may allow you to use social plugins which are provided and operated by third-party networking services (e.g. Facebook or Twitter) (the “Third-Party”), such as the Facebook “Like” button. These Third-Party services that operate these sharing tools may collect information about the pages you visited, your IP address, your browser type or any other information collected through their own tracking technologies. These Third-Party services that operate these sharing tools may also set a cookie to ensure the features are functioning properly. Your interactions with the social media functions and widgets located on our Website are governed by the privacy policies of the Third-Party services that provide them. If you use any of the social media functions or widgets on this Site, we strongly suggest you review the privacy policies of these Third-Party services that provide those functions and features.
7.1 General Uses.
We use your information, including Personal Information we collect about you for the following, but not limited, purposes:
- To provide, operate, maintain improve and promote our Products;
- To enable you to access and use our Website and order our Products;
- To send you technical notices, updates, support and administrative messages;
- To communicate with you and respond to any query or request you have submitted;
- To send you information you have requested from us;
- To send you information for marketing purposes and keep you posted on our latest product announcements, and upcoming promotional events (for opt-out instructions, see below);
- To provide customer service and support;
- To compile aggregated statistics about the operations and use of the Website and to better understand the preferences of our Customers;
- To alert you about a security announcement;
- To carry out other legitimate purposes for which we obtain your consent.
7.2 Legal basis (for EEA Customers only).
If you are from the European Economic Area (“EEA”), our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract, we will make this clear at the relevant time and advise you whether the provision of Personal Information is mandatory or not (as well as of the possible consequences if you do not provide Personal Information).
Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to that Personal Information. If we process Personal Information in reliance on your consent, you may be able to withdraw your consent at any time.
If you have questions about or need further information concerning the legal basis on which we collect and use Customer’s Personal Information, please contact us using the contact details provided under the “Contact Us” section below.
8.1 We may share your Information with our Service Providers.
We employ and contract with people and other entities that provide us with certain services, such as hosting, maintenance and security of our Website, analytics (collectively, our “Service Providers”) to assist in the provision of our Website. We provide these Service Providers with only the Personal Information they need to perform their services and work closely with them to ensure that your privacy is respected and protected. Unless we tell you differently, our Service Providers do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Service Providers. Please find below a list of the current Service Providers we use to assist in the provision of our Website:
- Analytics: Google Analytics;
- CRM: Zoho;
- Direct Marketing: ConstantContact;
- Quickbooks and Quickbase;
- Credit Card Processing: GoPayment (Quickbooks);
- Email service provider: Gmail;
- Shipping service provider: USPS, UPS, ShipStation.
8.2 We may share your information in the event of a change of control.
We may also transfer and assign your Information in the event we are sold, acquired, or a majority of our business is acquired by a third party.
8.3 We may share your information with our related companies.
8.4 We may share your information in response to legal requests.
We reserve the right to disclose information you provide to us as required by law, in response to legal process and law enforcement requests and as necessary or appropriate, in our view, to operate the Website, process registrations and to protect the rights or property of Infaco (including but not limited to disclosure where we believe that such disclosure would be necessary or appropriate to investigate and defend ourselves against any third-party claims or allegations) or to protect the rights, safety or property of our Customers or others.
Infaco may need to share and transfer your Personal Information with Service Providers who may be based outside the European Economic Area (EEA). We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights. We are relying on appropriate or suitable safeguards or specific derogations recognized under data protection laws, including the GDPR.
The European Commission has adopted standard data protection clauses, which provide safeguards for Personal Information transferred outside of the EEA. We may use Standard Contractual Clauses when transferring Personal Information from a country in the EEA to a country outside the EEA. If your Personal Information are affected, you can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.
Infaco is committed to ensuring the security of your Personal Information. We take reasonable precautions to protect the confidentiality and security of your Personal Information placed on our Website. Any Personal Information that we store is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.
You may access your Account information and our Website through the use of a password. To protect the confidentiality of Personal Information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. If you have any questions about the security of your Personal Information, you can contact us at firstname.lastname@example.org. We strive to take reasonable measure to protect your security. However, no security system is impenetrable we cannot guarantee that any information may be accessed, disclosed, altered or destroyed by any breach. For more details, please read our Security Policy.
10.2 Personal Information Retention.
We will retain the Personal Information we collect where we have an ongoing legitimate business need to do so or until delete your Account, whichever comes first. This is a case-by-case determination that depends on the nature of the data and why it is collected.
When you delete your Account or when we have no ongoing legitimate business need to process your Personal Information, we will either delete it or anonymize it.
For example, where we are processing Personal Information based on your consent, that you voluntarily submitted to us, we generally will retain the Personal Information for the period of time necessary to carry out the processing activities to which you have consented (subject to your right, under certain circumstances to erase some of your Personal Information, see below Section 11).
11.1 Promotional and Newsletter Communications.
11.2 Accessing, Correcting or Editing your Personal Information.
If you need to access, update, correct or editing your Personal Information associated with a Transaction or your Account, you can contact us at email@example.com and we will respond to your request within a reasonable time.
11.3 Deleting your Personal Information.
If you would like to delete your Personal Information associated with your Account or any Transaction, you can contact us at firstname.lastname@example.org and we will respond to your request within a reasonable time. We will not retain any Personal Information after deletion, except the retention of certain information as required by law or for legitimate business purposes.
11.4 Exporting your Personal Information.
If you would like to export your Personal Information, you can contact us at email@example.com and we will send your exported data, free of charge, within a reasonable time.
11.5 Request that we restrict your Personal Information.
You can ask us to restrict (i.e. keep but not use) your Personal Information where:
- its accuracy is contested (see Section 11.2 above), to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal data following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- To protect the rights of another natural or legal person.
11.6 Request that we stop using your Personal Information.
You may ask us to stop accessing, storing or using your Personal Information where you believe we don’t have the appropriate rights to do so. For such request, you may contact us by email at firstname.lastname@example.org. We will investigate then respond to your request within a reasonable time.
We will not charge you any fee to exercise any of your rights in relation to your Personal Information unless your request for access to information is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.
11.8 Time to respond to your requests.
We aim to respond to any valid requests within one month unless it is particularly complicated, or you have made several requests in which case we aim to respond within three months. We will let you know if we are going to take longer than one month. We might ask you if you can tell us what exactly you want to receive or are concerned about. This will help us to action your request more quickly.
If you are a California resident, California law permits you to request information regarding the disclosure by Infaco of your Personal Information to a third party for that third party’s direct marketing purposes. To make such request and opt out at any time after granting approval, please contact us by email to email@example.com.
The Website is not directed at children under the age of 18. We do not knowingly solicit or collect Personal Information from children under the age of 18.
If you have any questions or concerns about how your Personal Information is handled, please direct your inquiry to firstname.lastname@example.org.