PRIVACY POLICY & NOTICE

This Privacy Policy & Notice (this “Policy”) describes how your personal information is collected, used, and shared when you visit or make a purchase from Siprocal.com (the “Site”). Siprocal, Inc., including its affiliates and related entities (“Siprocal”, “we”, “us”, or “our), is committed to protecting the privacy of personal information and data we process as a controller in the normal course of our business and through the sale of our services and products.

PLEASE READ THIS POLICY CAREFULLY BEFORE USING OUR SITE OR PURCHASING OUR PRODUCTS OR SERVICES.   

1.        INFORMATION WE COLLECT

When you visit the Site, we may collect Personal Information about you and your device, which are comprised of several types of information (including identifiers, commercial information, characteristics and descriptions, and internet or other network activity). Please refer to the definitions below as you review this Policy to better understand what kinds of Personal Information we may gather.

“Personal Data” or “Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. Under applicable U.S. consumer privacy laws, Personal Information can be broken into numerous categories—for example, identifiers or commercial purchase information. In addition, Personal Information may also include “Order Information” (which is defined below).

“Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

“Sensitive Information” means Personal Information that is considered sensitive, highly protected, within a special category, or unique under applicable data privacy laws, such as social security numbers or other government issued identification. WE GENERALLY DO NOT COLLECT INFORMATION THAT IS CONSIDERED SENSITIVE UNDER DATA PROTECTION LAWS.

Information You Provide to Us:

We may collect Personal Data from you through use of the Site, such as your first and last name, e-mail, mailing address, and phone number. In general, we collect this information directly from you, or automatically from you, when you visit and interact with the Site.

If you provide us feedback, post an event or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the form, in order to send you a reply.

We may also collect Personal Data at other points in the Site that state that Personal Information is being collected.

Information Collected via technology: We automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

YOU ARE NOT REQUIRED TO PROVIDE PERSONAL INFORMATION TO US. However, if you do not provide us with Personal Information, you may not be able to use certain features of the Site or our products and services.

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number). We refer to this information as “Order Information”.

2.        HOW DO WE USE YOUR PERSONAL INFORMATION

We use the information that we collect generally to:

–         Communicate with you;

            –         Operate, maintain, and provide features of the Site;

–         Comply with legal obligations and protect our and your rights under applicable laws;

–         Screen our orders for potential risk or fraud; and

–         When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services (subject to the opt-out rights below).

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

Creation of Anonymous Data.

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of, and improve navigation on, the Site. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

3.        SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above, and to support our Site and related services. We also use Google Analytics to help us understand how our customers use the Site — you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

4.        DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

5.        YOUR RIGHTS

International Privacy Rights

Pursuant to applicable data protection laws (including EU and UK privacy laws), you may contact us to exercise certain rights concerning your Personal Information, including the right to:

–         Erase or delete your Personal Information.

–         Access your Personal Information.

–         Restrict the processing of your Personal Information.

–         Correct, update, or rectify your Personal Information.

–         Receive a copy of your Personal Information (data portability).

–         Object to the processing of your Personal Information.

–         Withdraw consent to the processing of your Personal Information, if we relied on your consent to collect and process your Personal Information.

For purposes of international privacy laws, the legal basis of our processing of your Personal Information, as described in this Policy, is our legitimate interests where those interests are not overridden by the impact on you (unless our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, please contact us at the address below. Further, if we process your Personal Information based on a legitimate interest, you have the right to object to this processing.

U.S. Privacy Rights

As a resident of certain U.S. jurisdiction, you may also have the right to: (i) request that we disclose the categories and specific pieces of Personal Information we have collected and disclosed about you, including information concerning whether we have shared your Personal Information for cross-context behavioral advertising; (ii) know whether we have sold your Personal Information; (iii) request information about our disclosure of Personal Information to third parties and our service providers, including for their direct marketing purposes; and (iv) opt-out of us sharing your Personal Information with third parties and our service providers. You also have the right to lodge a complaint with a supervisory authority. Depending on where you are located (for example, in California, Colorado, Utah, Connecticut, and Virginia), some of these rights may not apply or may be subject to limitations. For example, we may limit the number of requests you make or charge reasonable fees as legally permitted. You will not face discrimination for exercising your rights with respect to your Personal Information.

You or your authorized agent may contact us (at the contact information below) to exercise these rights set out above. Your request must provide sufficient information that allows us to reasonably verify you are the person about whom the request is made and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

6.        STORAGE OF PERSONAL INFORMATION AND INTERNATIONAL TRANSFERS

To support our Site and products, we may collect, store, and process your Personal Information on our premises, data platforms, and private cloud storage solutions in the United States or with those affiliates and third parties with whom we share your Personal Information as described in this Policy. The transfer or disclosure of your Personal Information to our U.S. systems or such third parties, including in the United States, is necessary for the implementation of pre-contractual measures taken at your request when purchasing our products, for fulfillment of online orders, and to enable Siprocal and our service providers to give essential support to the Site.

To ensure the protection of Personal Information we transfer or disclose to overseas recipients, we take necessary and appropriate steps to protect the security and privacy of your Personal Information in accordance with applicable law (including implementation of Standard Contractual Clauses approved by the European Commission and authorities in the United Kingdom, as updated from time to time, and appropriate data transfer and processing agreements).

7.        CHANGES

We may update this Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

8.        SECURITY MEASURES

We use technical and organizational measures, such as a secure server and encryption technologies, to protect Personal Information against loss, misuse, and unauthorized access, use, or alteration. We review our security measures regularly and consider new measures as appropriate. However, we cannot guarantee the complete security of these measures, so please exercise caution when submitting Personal Information online.

9.        CHILDREN’S PRIVACY

Our Site is not intended for children under 16 years of age. If you are under the age of 16, please do not provide any Personal Information to us through the Site or purchase any products or services through the Site. We do not knowingly collect Personal Information from children under the age of 16, and if you believe we might have any information from or about a child under 16, please contact us at the information set out below.

10.      DATA RETENTION PERIOD

We retain Personal Information for a reasonable period to fulfill the purposes for which we collected it (as outlined in this Policy), including to defend our rights under product sales and contracts with you. If we no longer reasonably need Personal Information for such purposes, we will, at our election and in accordance with applicable data protection laws, delete it from our records, anonymize the Personal Information, or archive the Personal Information in a manner consistent with industry standards for protection and retention of Personal Information, unless applicable law or legal considerations necessitate a longer retention period.

11.      CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint or exercise your rights above, please contact us by e‑mail at marketing@siprocal.com.