Last Updated and Effective as of: June 4, 2018
Your provision of your Personal Information to us is completely voluntary. “Personal Information” is information that can specifically identify you. We do not collect Personal Information unless you submit that information to us. Categories of Personal Information we collect include:
- Identity Data,which includes name or other similar identifiers.
- Contact Data,which includes address, email address and telephone numbers.
Additionally, we may also collect certain other types of information that, along with Identity Data and Contact Data may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:
- Technical Data,which includes internet protocol (IP) address, device and operating system used to access website.
- Usage Data,which includes information about how you use our Website and services.
- Marketing and Communications Data,which includes your preferences in receiving marketing from us.
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
In addition, we may also collect information that is not Personal Information (“Non-Personal Information”). We may aggregate Personal Information so that the aggregated information does not personally identify you or anyone else, such as by using Personal Information to calculate the percentage of our customers who live in a particular area (“Aggregate Information”). Because Non-Personal Information does not personally identify you, we may collect, use and disclose Non-Personal Information for any purpose permitted by law and subject to the section titled “Additional EU Disclosures”. In some instances, we may combine Non-Personal Information with Personal Information. If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information.
Information Usage and Disclosure:
Besides using your Personal Information ourselves, we may send your Personal Information to other companies, affiliates and third parties to help us process your Personal Information for the purposes set out in this policy.
We use Personal Information and other information as described herein:
- to contact you about our services and provide you with our services,
- to personalize your experience with us,
- to respond to your direct inquiries,
- to add you to our mailing lists and send you emails from time to time.
We may also share your information with third parties such as website hosting, data analysis, e-mail delivery services, and other similar services. These third parties may have access to Personal Information necessary to perform their functions, but may not use it for other purposes.
We will not sell your Personal Information to any third party not affiliated with G&S without your consent except in connection with the sale or merger of G&S or the division responsible for such services.
Additionally, we may disclose Personal Information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) for legitimate business interests.
We may use Aggregate Information and Non-Personal Information to improve and enhance your experience on the Website and for our market research activities. For example, and subject to section titled “Additional EU Disclosures”, we may share Aggregate Information and Non-Personal Information with unaffiliated third parties, such as business partners, in a form in which means the shared information will not contain nor be linked to any Personal Information.
Please note that if you specifically consent to additional uses of your Personal Information, we may use your Personal Information in a manner consistent with that consent.
Cookies and Similar Technology:
|Google Analytics||Persistent, first party||Used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect certain information, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.||Click here for more information on Google Analytics: https://support.google.com/analytics/answer/6004245|
|DoubleClick||Persistent, session and third party||Provides information about visitors, such as the websites they visit before and/or after visiting a website||Click here for more information about DoubleClick: http://www.google.com/intl/en/policies/privacy/|
As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to the Service. We may collect and use clickstream data to anonymously determine how much time visitors spend on websites, how visitors navigate throughout websites and how we may tailor our Service to better meet consumer needs. This information will be used to improve our Service and our services. Any collection or use of clickstream data will be anonymous, and will not intentionally contain any Personal Information.
To stop, restrict or disable the placement of cookies, please see the “Opt Out” section below.
The security of your information is very important to us. We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and G&S, or information stored on the Website or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Website demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact section below.
We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Website and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use anonymous or aggregated data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
Other Websites and Social Networking Services:
Our Website may contain links to other websites not maintained by G&S. Other websites may also reference or link to our Website. The inclusion of a link on the Website does not imply endorsement of the linked site by us. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with our Website, or for the privacy practices of third party Internet advertising companies. We encourage you to be aware when you leave our Website, or surf the Internet, and to read the privacy statements of each and every website that you visit.
The Website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.
To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at firstname.lastname@example.org. We will process your request within a reasonable time after receipt.
If you supply us with your mailing address online you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by calling us at the number provided above. Please provide us with your exact name and address. We will be sure your name is removed from the list.
Persons who supply us with their telephone numbers may receive telephone contact from us with information regarding new products and services or upcoming events. If you do not wish to receive such telephone calls, please let us know by sending us at email@example.com or tell the representative on the phone when you receive our call.
The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. To be clear, cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your desktop browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. For example, if you have opted out on your computer browser, that opt-out will not necessarily be effective on your mobile device. In the event we are performing cross device matching (as described above) Once you have opted out on one device (“Opted-Out Device”), we will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes and we will not use data from another device for interest-based advertising purposes on the Opted-Out Device.
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve Personal Information from your device without your knowledge.
Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.
Changes to policy:
We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time. Your continued use of the Website following the posting of any changes to this policy means you accept such changes.
Additional EU Disclosures:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where you have consented to a certain use of your personal data.
- Where we need to comply with a legal or regulatory obligation.
To the extent permitted under applicable laws, we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.
Gibbs & Soell, Inc. Is the data controller of all personal data collected through our Website. To contact us, please see the section titled “Contact Us”.
If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you have a complaint, please contact our privacy manager can be contacted here: firstname.lastname@example.org.
Provision of personal data and failure to provide personal data:
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.
Collection of personal data from third party sources:
We do not collect personal data about you from various third parties and public sources.
Withdrawing your consent:
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at email@example.com.
We may transfer personal data from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. If we transfer personal data outside the EU to a processor, such transfer will be in compliance with the requirements of the GDPR.
Use of your personal data for marketing purposes:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.
To see how you can opt out of marketing communications, please see the section titled “Opt-Out”.
Data Subject Rights:
If you are a situated in the EU, under the General Data Protection Regulation (“GDPR”), as a data subject, you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
To exercise your rights under the GDPR, please contact us at firstname.lastname@example.org. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
Information Relating to Children
Our Website is intended for ages 18 and over. We do not knowingly collect Personal Information from children. When we become aware that Personal Information (or other information that is protected under applicable law) from a child under 13 (or such other age as may be restricted under local law) has been collected, we will use all reasonable efforts to delete such information from our database.
Website Terms and Conditions:
Use of this Website is governed by, and subject to, the legal notices contained at “Term and Conditions”. Your use, or access, of the Website constitutes your agreement to be bound by these provisions.
For questions or concerns relating to privacy, we can be contacted at: email@example.com. Our mailing address is 60 East 42nd Street, 44th Floor, New York, NY, 10165. You can also reach us by telephone at 212-697-2600. If you are situation in the EU and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.