Collection and Use of Personal InformationIf you use the Websites, personal information that identifies you as an individual or that relates to an identifiable person (“Personal Information”) may be collected and processed by Hexacom employees. In general, we collect and process Personal Information when you knowingly provide it to us, such as:
- Job Title
- Postal address (including billing and shipping addresses)
- Country of operation (may be different than office location)
- Telephone number
- Email address
- Company name and type of business
- Job seeker
- Vendor or supplier
- Investor or financial analyst
- Teacher, professor, or academic researcher
- Payment information, such as your payment method and billing address
How we collect your Personal InformationHexacom collects your information in different ways. Below are some examples of how we may collect your information.
- Directly From You. For example, when you:
- Register for an account.
- Purchase our products or services.
- Sign up to receive promotional communications.
- Participate in one of our promotional sweepstakes, contests, surveys, or focus groups.
- Post a product review.
- Submit a request to our customer service team.
- Interact with Hexacom social media pages.
- Passively. For example, your Internet domain or IP address, as part of the operation of the Websites or during the course of your activities on or use of the Websites.
- From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from:
- Our business partners.
- Social media sites, including Facebook, Twitter, YouTube and Instagram.
- By Combining Information. For example, we may:
- Combine information that we collect offline with information we collect through our Websites.
- Combine information we collect about you from the different devices you use to access our Websites.
- Combine information we get from third parties with information we already have about you.
How we use your Personal InformationWe may need to collect and process these types of Personal Information in order to provide the Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the Services, including the following:
- To contact you:
- To respond to your inquiries and fulfill your requests, such as to send you newsletters.
- To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions and policies.
- To send you marketing and informational communications such as the latest industry publications and resources on topics you have selected, where you have chosen to receive such communications.
- To execute any agreements we may enter into with you. For example, to confirm your attendance at an event we organize.
- To tailor our Websites in a way that is most relevant to you based on your preferences (e.g. information you have voluntarily provided to us, or your previous visits to our Websites).
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- Assessment and acceptance of a customer.
Sharing with other Hexacom companiesWe may share your Personal Information with our affiliates for the purposes described in this Statement. To the extent that these entities have access to your information, they will follow privacy practices no less protective than the practices described in this Statement, to the extent allowed by law.
How Personal Information is shared with third parties
- To carry out a transaction or provide Services for you (such as packaging, sending and delivering purchases and information to you, clearing credit card transactions, or performing statistical analyses of our Services).
- To service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
- To the extent we believe to be 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 or in response to activities that are unlawful or a violation of Hexacom rules for use of the Website; (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; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- For other reasons we may describe to you.
Sensitive InformationWe do not knowingly collect sensitive Personal Information (such as, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) from you via the Websites. We also ask that you not send us, and you not disclose to us, any sensitive Personal Information on or through the Websites or otherwise.
Other information we may collect, including ‘cookies’“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
Collection of Other InformationWe and our service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
Uses and Disclosures of Other InformationWe may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated as Personal Information as long as it is combined.
Security measuresHexacom has implemented technological and operational security processes to protect your personally identifiable information from loss, misuse, alteration, or unintentional destruction. While no security measure can guarantee against compromise, Hexacom regularly reviews and updates its security measures in an effort to provide appropriate security for all information held by Hexacom. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Modifications to StatementHexacom reserves the right to change, modify, or update this Statement at any time. Your use of the Services following these changes means that you accept the revised Privacy Statement. We will notify you of any material changes to our Policy as required by law.
California privacy rightsIf you reside in California, you have the right to ask us one time each year if we have shared Personal Information with third parties for their direct marketing purposes. To make a request, please contact us via the email provided on the Website. Indicate in your communication that you are a California resident making a 'California Shine the Light' inquiry.
EU privacy rightsWe want to draw your attention on your rights regarding your Personal Information you provided us with:
- You can request Hexacom to access to and rectify or erase your Personal Information, or to restrict or object to their processing;
- You can request Hexacom to exercise your right to data portability;
- You can withdraw at any time your consent to the processing of your personal information of other purposes than (i) the execution of an agreement between yourself and Hexacom or (ii) the compliance of Hexacom with legal obligation to which it is subject, it being specified that such withdrawal shall not affect the lawfulness of processing based on such consent before such withdrawal;
- You can lodge a complaint with the relevant European Union or local Member State authorities.
Your rightsHexacom wants to maintain only accurate information about users of the Website. If you would like to request access to Personal Information that you have previously provided to us you may contact us by sending inquiries to the Contact Information below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information to which you would like access and your purpose for making the request. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
Data retentionHexacom will not retain your Personal Information longer than is necessary and permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
ChildrenHexacom takes children's privacy seriously. The Websites are not directed to individuals under the age of thirteen (13) and we ask children under the age of 13 not to send any personally identifiable information to the Websites without the consent of their parents or guardians. Hexacom encourages all parents and guardians to instruct their children in the safe and responsible use of personal information on the Internet. Hexacom will not knowingly collect, use, or disclose to third parties any Personal Information collected from children, and we are committed to complying with applicable laws and requirements, such as the United States' Children's Online Privacy Protection Act (COPPA).
Jurisdiction and cross-border transferIn nearly all cases your Personal Information may be collected or processed by, and transferred to, Hexacom facilities in the United States and in other countries where Hexacom does business. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Websites you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
If you are located in the European Economic Area (EEA): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information.
Linked WebsitesWe may provide links to third party sites. Since we do not control these websites, we encourage you to review the privacy statement posted on these (and all) third party sites. Hexacom is not responsible for the privacy statements or practices of sites and services controlled by companies or organizations other than Hexacom. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
Contact informationCustomers should direct comments or questions regarding this Statement to CustomerService@TheOFMP.com. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
Effective Date: 9 September 2018