Effective Date: December 12th, 2021
1. Who Collects Your Information On Our Service?
We do. Under the CCPA we are a “Business”. We collect information from you on the Service, and we are responsible for protection of your information.
2. What Information Does Sofidel Collect?
A - Personal Information. We collect certain personal information about you, which may be supplied when you sign-up for the Service, when you complete a survey, when you create or update an account, when you use the Service, when you request services, otherwise when you submit such information to us, from social media platforms which are integrated into the Service, and from other third parties. We only collect basic personal data about you. The types of personal information we collect and save include:
Contact and account information such as name, email address, mailing address, phone number, user name, location based information, and other types of personal information collected through the Platforms, if you opt-in to the integration;
Technical information collected in our logs. Such information may include standard web log entries that contain your IP address, device identifiers, first party cookies (both session and persistent), first and third party cookies, notifications when you have read an email that we sent you, device identifiers (e.g. UDID, MEID, and IMEI), web beacons, page URL and timestamp.
You may also provide us information when you interact with us through email, online chat, messaging functions within the Service, or otherwise. We may retain such information in order to provide you with Services, and you agree that we may share this information as needed with other users in order to resolve any issues that may arise between you and another user of the Service.
The Service may be integrated with third party social media platforms, such as Facebook, LinkedIn, Instagram, and others (collectively, the “Platforms”). If you choose to interact with the Platforms through the Service, the Platforms may make additional PII about you available to us.
If you permit such access in order to use certain features, the Service may also record pictures, audio, and video. The Service may also make phone call or send text messages, create push notifications on your device, and add icons and shortcuts other than for the App (e.g. for certain web tools).
B - Non-personal Information. Non-personal information is anonymous or non-personally identifiable information about you, including but not limited to links and materials posted, information about your web browser, pages visited, length of session, device type, and similar non-personal data.
Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Service may utilize web beacons, pixel tags, cookies, embedded links, and other commonly used information-gathering tools. Through collecting your IP address, we may be able to approximate your geographic location, however, unless and until this is information is paired with your PII, it cannot be used to identify you. If non-personal information is paired or linked to any of your PII, we will treat that non-personal information as if it was also PII.
C - Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, location, device information, session information, page views, operating system, referral channels and sites, traffic sources, conversions, gender and approximate age.
3. Why Is My Information Being Collected?
We accept and gather information in an effort to provide the Service to you. We need to collect your personal information to, among other things, respond to your requests for information, to add you to our email lists, as part of your participation in contests, and generally to allow the Service to operate. We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you.
4. How Do We Use the Information We Collect?
A - We use the personal information you provide for the purposes for which you have submitted it including:
Internal Uses. We may use your PII to respond to your inquiries, to fulfill your requests for information, track usage trends, conduct experiments, fraud prevention, develop and improve the Service and other offerings, and perform research and analytics.
Creating and Maintaining Your Account. We use your PII to create and maintain an account for you to allow you to use the Service.
Serve You Targeted Advertisements. We may use your PII to serve you advertisements with the Service that are targeted to your interests.
Contests. From time to time, we may offer certain contests. Participation in such contests will be voluntary, but we may process your PII in connection with such contests, such as videos of you, that you submit as part of a contest.
Sending You Mail. We may use your PII to send mail to your postal address, including, but not limited to, in connection with certain contests that we offer which you may elect to participate in.
Social Media Integration. We may use your PII to, at your request, integrate your social media accounts with the Service, and to provide to you the social media features of the Service.
B - We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Sites and App are used, as well as to offer you programs or services.
5. Do We Share Your Personal Information?
We will not share your personal information except: (a) for the purposes for which you provided it; (b) with your consent including, but not limited to, third parties whose products or services may be of interest to you; (c) as may be required by law or as we think necessary to protect our organization (including the defense of legal claims) or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); (d) with our parent entity and other affiliates, including but not limited to, Soffass SpA and Sofidel SpA for the purposes described in Section 4 above and as otherwise permitted under applicable law; (e) marketing and business partners for commercial purposes; or (f) with persons or organizations with whom we contract to carry out internal operations or business activities. We may also share aggregate information with others, including affiliated and non-affiliated organizations.
We do not disclose any PII to, nor do we have any connection or partnership with, social media sites, platforms, or companies.
Finally, we may transfer your PII to a third party, or our successor-in-interest, in relation to, or in the event of, a merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control. After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law.
6. Are There Other Ways My Personal Data Could Be Shared?
You may elect to share certain personal information with individuals or with the public via your use of the Sites, App, or Service. In this case, you will control such sharing via settings that we provide. For example, the Service may make it possible for you to publicly share information via Platforms such as Facebook, or Instagram. Be aware that when you choose to share information with friends, or with the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred. Always use caution when sharing information through the Service. You understand and agree that we are not responsible for any consequences of your sharing of information through and beyond the Service.
7. How Can You Access And Control Your Information?
After becoming a user of the Service, with the exception of your email address (for administration purposes), you may revise or edit your information by logging into the Service, or by sending an email to firstname.lastname@example.org. For instructions on how you can further access your personal information that we have collected, obtain a copy, or how to correct errors in such information, please send an e-mail to email@example.com.
We will also promptly stop using your information and remove it from our servers and database at any time upon your e-mail request to firstname.lastname@example.org. You may opt-out of the use of your personal information by the Service to send you promotional and/or marketing emails by using the unsubscribe feature in the email or by sending us an email to email@example.com with “Opt-Out” in the subject line. Similarly, you may at any time revoke the consent you previously provided for the sharing of your personal information with third parties by emailing us at firstname.lastname@example.org with “Do not share my information” in the subject line. If you wish to once again permit the sharing of your PII with third parties to regain certain benefits, functionality, or otherwise, you may do so at any time by emailing us at email@example.com with “Opt-In” in the subject line. Finally, you may opt-out of the use of your PII for purposes other than which you provided it, including, but not limited, inclusion in an online directory, by emailing us at firstname.lastname@example.org with “Opt-Out” in the subject line. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information.
8. How Do We Store and Protect Your Information?
A - After receiving your personal information, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place, including but not limited to dedicated servers, to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.
B - If you are visiting the Sites from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.
C - We store your personal information until the earlier of: your request us to remove it from our servers; applicable law requires it to be removed; or our internal retention policies indicate it is time for removal. We store our logs and other technical records indefinitely.
A - To enhance your online experience with us, our web pages may presently or in the future use "cookies." Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Although it may be possible to turn off the collection of cookies through your device or browser, certain features of the Services may not function properly without the aid of cookies.
For more information on how Google uses data when you use our Sites or Service, please follow this link: https://policies.google.com/technologies/partner-sites.
You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info or http://optout.networkadvertising.org if you are based in the United States, or http://www/youronlinechoices.eu/, if you are based in the EEA.
C - Sofidel or our service providers may also use "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Sofidel Sites and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of the Sofidel Sites, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.
D - As you use the internet, you leave a trail of electronic information 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 reveal the type of computer and browsing software you use and the address of the website from which you linked to the Sofidel Sites. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our site.
E - Do Not Track. At present, the Sites do not specifically respond to browser do-not-track signals.
10. Collection of Information by Others.
Our Terms of Service document may identify certain third party websites to which we may provide links, and that you may click on our Sites. In addition, you may give us your consent to share your personal information with certain third parties. Please check the privacy policies of these third parties and their websites to learn how they collect, use, store and share information that you may submit to them, that we share with them with your consent, or that they collect, as their privacy practices may differ notably from ours. Please note, we will not be responsible for a third party’s use of your personal information that you provide to them, or that we provide to them with your consent.
11. Children and Young People’s Information.
We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the CCPA and the Children's Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC's website (www.ftc.gov) for more information. If you have concerns about our Site(s), wish to find out if your child has accessed our services, or wish to remove your child's personal information from our servers, please contact us at email@example.com. Our Site(s) will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with COPPA. If you believe that your child under 13 has gained access to our Site(s) without your permission, please contact us at firstname.lastname@example.org.
12. California Privacy Rights.
To the extent that the CCPA applies to our practices with respect to PII and you currently reside in California, the CCPA provides you with certain rights.
A - Consumers Rights Under the CCPA.
California consumers have the right to request that we disclose Personal Information we have collected about them in the previous 12 months including, but not limited to, the categories of information collected by us, the source(s) of such information by category, and the purpose for collecting such information. This right may not be exercised more than twice in a 12 month period. In the previous 12 months, we have collected the following categories of Personal Information about consumers;
Identifiers. Identifiers can be your name, unique personal identifiers (device identifier, IP Address, cookies, beacons, pixel tags, mobile ad identifiers), email, phone number, and similar information;
Personal Information Under the California Customer Records Law (Cal. Civ. Code §1798.80) (“CCRLPI”), which is similar in nature to Identifiers;
Commercial Information. Commercial information includes records of personal property, products or services purchased, obtained or considered, or other purchased or consuming histories or tendencies;
Geolocation Data. Such geolocation data may include GPS data;
Internet/Network Activity. Internet Activity Information includes browsing history, cookies, search history and a consumer’s interaction with a website;
Audio, electronic, visual, and similar information;
Professional and employment related information; and
Inferences drawn from any other category of Personal Information.
As a California consumer, you also have the right to request that we tell you which of your Personal Information we have disclosed for a business purpose, or sold, in the previous 12 months, if any. In the past 12 months, we have disclosed Personal Information falling under the following categories:
Internet/Network activity; and
You also have the right to request the deletion of the Personal Information that we have collected from you at any time. However, we may not be required to comply with such request under several circumstances including, but not limited to, when the data is necessary for the underlying transaction, to comply with applicable law, to detect security incidents, to debug glitches, and for our internal purposes.
In the event that you exercise one of your rights under the CCPA, you have the right to not be discriminated against by us in any way, including by the denial of goods or services, providing you with a different level of goods or services, or charging you different prices or rates for the goods or services, unless the change in price is reasonably related to the value you receive from your Personal Information.
B - How do you exercise your rights under the CCPA?
You may submit your requests to exercise your rights under the CCPA by emailing us at email@example.com and putting CCPA in the subject line. When submitting a request via email, please indicate which CCPA right you wish to exercise and provide sufficient information to allow us to locate your file.
We will acknowledge receipt of your request within 10 business days of receiving it, and will do our very best to respond within 45 calendar days of receipt of your request, and in no event will our response come more than 90 days after receiving your request. If we are unable to provide our response within the first 45 day window, we shall notify you as soon as we become aware of the possible delay and provide an explanation of why additional time is needed to respond.
Before we respond to any CCPA based requests to access or delete your Personal Information, we will take steps to reasonably verify the identity of the person making the request (“Requestor”) to make sure it’s you, or your authorized agent. We do this to this avoid disclosing your information to third parties and bad actors, not to inconvenience you in any way. To do this, we will ask the Requestor to confirm at least two pieces of information that we have in our files. As the sensitivity of the information being requested goes up, we will ask the Requestor to confirm more pieces of information. If an agent is acting on behalf of the consumer, we will need to also verify the agent’s identity and their authority to act on the consumer’s behalf. For requests to delete information, after verification, we will confirm the consumer’s desire to delete one final time before actually deleting the information. If the identity of the Requestor cannot be reasonably verified, either as the consumer or their agent, then in order to protect that consumer, we shall not disclose the Personal Information requested.
13. Our Contact Information.
Copyright © 2021 Sofidel America Corp. All rights reserved. The Service is the property of Sofidel, and is protected by national and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.