Jim Hester Wholesale Division Ltd.

Privacy Policy

Jim Hester Wholesale Division Ltd. attaches great importance to the protection of personal data and respects your desire for privacy. In the following we inform you about the collection of personal data when using our website. Should you have any further questions regarding the handling of your personal data, please do not hesitate to contact us (see contact information below).

Who is responsible for the processing (PIPEDA; Art. 4 No.7 GDPR) ?

For Customers/ Visitors of our Homepage worldwide

Vincit Global Inc.
1395 Benvenuto Ave.
Brentwood Bay, BC V8M 1J5
Canada

Contact option

 Data Protection Officer Email: privacy@vincit.global

Which (personal) data do we collect?

  • name, email address
  • IP address
  • date and time of the request
  • time zone difference to Greenwich Mean Time (GMT)
  • content of the request (specific page)
  • access status/HTTP status code
  • amount of data transferred in each case
  • visiting time – How long a user was on the site and how long on each subpage
  • referrer – From which source a user comes to the website
  • inferences about personal preferences and attributes drawn from profiling (via cookies)
  • browser information (name of the browser used, Viewport, Screen resolution, JavaScript, Operating system, Language)

 PIPEDA (Personal Information Protection and Electronic Documents Act) Policy

Intent

The Personal Information Protection and Electronic Documents Act (PIPEDA) establishes rules to govern the collection, use, and disclosure of personal information in a manner that recognizes the right to privacy of individuals with respect to their personal information and the need of organizations to collect, use, or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances. Jim Hester Wholesale Division Ltd. is committed to protecting and respecting the personal information of its customers, employees, business partners, and all other entities it interacts with in accordance with PIPEDA. This policy will provide guidelines to ensure that Jim Hester Wholesale Division Ltd. remains compliant with PIPEDA requirements.

Definitions

Breach of security safeguards  – The loss of, unauthorized access to, or unauthorized disclosure of personal information resulting from a breach of an organization’s security safeguards, or from a failure to establish those safeguards. 

Personal information – Information about an identifiable individual.

Security safeguards  – Security safeguards include the following:

  • Physical measures, for example, locking filing cabinets and restricted access to offices;
  • Organizational measures, for example, security clearances and limiting access on a “need-to-know” basis; and
  • Technological measures, for example, the use of passwords and encryption.

 

Significant harm – Includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record, and damage to or loss of property

Guidelines

Compliance

The following guidelines have been implemented to ensure Jim Hester Wholesale Division Ltd. remains compliant with PIPEDA requirements. The personal information of Jim Hester Wholesale Division Ltd. employees, customers, clients, business partners, etc., must be managed so as to meet the following PIPEDA requirements:

  • All personal information in Jim Hester Wholesale Division Ltd. possession or custody must be protected in an appropriate manner.
  • Individuals must be informed as to why personal information is being collected.
  • Consent must be obtained for the collection of information.
  • The consent of an individual is only valid if it is reasonable to expect that the individual understands the nature, purpose, and consequences of the collection, use, or disclosure of the personal information.
  • Personal information may only be collected without consent if:
    • The collection is clearly in the interests of the individual and consent cannot be obtained in a timely way;
    • It was produced by the individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was provided;
    • The collection is made for the purpose of making a disclosure; or
    • Any other reason as defined in PIPEDA’s section 7. (1).
  • Individuals have the right to withdraw their consent.
  • Personal information collected is only collected, used, or disclosed for purposes that a reasonable person would consider appropriate in the circumstances.
  • Personal information is used only for the purposes for which it was collected, except with the consent of the individual or as required by law.
  • Personal information is retained only for the period of time that it is reasonably required.
  • Personal information is destroyed that is no longer required using a safe, secure, and effective manner (e.g., shredding).
  • All personal information collected is accurate.
  • Individuals are allowed to gain access to their personal information, and make corrections as appropriate.
  • Appropriate security and safeguards are employed for the protection of personal information.
  • Access to personal information is limited to authorized personnel who have a legitimate need to access the information.
  • Consent must generally be obtained prior to the release of personal information to any third party.
  • Consent to disclose personal information to a third party is not required if:
    • Jim Hester Wholesale Division Ltd. has reasonable grounds to believe that the information could be useful in the investigation of a contravention of the laws of Canada, a province/territory, or a foreign jurisdiction, and the information is used for the purpose of investigating that contravention;
    • It is used for the purpose of acting in respect to an emergency that threatens the life, health, or security of an individual;
    • The information was produced by the individual in the course of their employment, business, or profession, and the use is consistent with the purposes for which the information was produced; or
    • Any other circumstances as defined in PIPEDA’s section 7. (2) are met.
  • The forms of information being collected must be identified and communicated to the individual as well as the rationale for the collection of these forms of information.
  • Individuals must be notified and consent must be obtained prior to using personal information for any reason other than those provided at the time of collection.

 

In addition to the above requirements, Jim Hester Wholesale Division Ltd. will designate a representative to hold accountability for the organization’s compliance with PIPEDA. The representative will hold responsibility for the management of the personal information policies and procedures of Jim Hester Wholesale Division Ltd..

  • The representative shall be the Privacy Manager

 

The PIPEDA representative shall be responsible for: 

  • Developing and implementing policies and practices under PIPEDA including:
    • Procedures that address the collection, use, retention, destruction, and management of personal information;
    • Procedures for protecting personal information;
    • Procedures for complaints and inquiries; and
    • Staff training on PIPEDA obligations.
  • Employing privacy agreements/contracts to ensure the protection of personal information where the information must be provided to a third party.
  • Reviewing policies, practices and procedures on an annual basis, or as needed, making appropriate revisions.

 

Breaches of Security Safeguards

Reporting Breaches

If Jim Hester Wholesale Division Ltd. becomes aware of a breach of our security safeguards that compromises the privacy of the personal information retained by the company, the following action shall be taken:

  • The Privacy Manager is responsible for coordinating the response to the breach and ensuring that all reasonable action is taken to address the breach.
  • The Privacy Manager will notify the Privacy Commissioner of the breach in the prescribed form and manner as soon as feasible once Jim Hester Wholesale Division Ltd. has determined that a breach has occurred.
  • Jim Hester Wholesale Division Ltd. will comply to the greatest extent possible and in a timely manner with any requests, orders, or other instructions from the Office of the Privacy Commissioner in order to respond to and address the security breach.
  • Jim Hester Wholesale Division Ltd. shall maintain records of every breach of security safeguards, and will provide the Privacy Commissioner with access to, or a copy of, a record of a breach, at the request of the Commissioner.

 

Notifying Affected Individuals

Determining Whether a Real Risk of Significant Harm Exists

Jim Hester Wholesale Division Ltd. will assess the following factors when determining whether a security breach constitutes a real risk of significant harm to an individual or individuals:

  • The sensitivity of the personal information involved in the breach;
  • The probability that the personal information has been, is being, or will be misused; and
  • Any other prescribed factor.

Notifications

Our Data Protection Officer is responsible for ensuring that all individuals affected by the breach for whom the breach creates a real risk of significant harm are notified at the earliest available opportunity, subject to any legal restrictions. Notifications shall:

  • Contain sufficient information to allow the individual to understand the significance to them of the breach and to take steps, if any are possible, to reduce the risk of harm from it or to mitigate that harm.
  • Contain any other prescribed information.
  • Be conspicuous and given directly or indirectly to the individual in the prescribed form and manner as legislatively required as the situation dictates.
  • Be given as soon as feasible after the organization determines that the breach has occurred.

 

In addition to the individual(s) affected by the breach, Jim Hester Wholesale Division Ltd. may notify other parties of the breach or disclose personal information relating to the breach, subject to the following guidelines:

  • Jim Hester Wholesale Division Ltd. shall notify other organizations, government institutions, or part(s) of government institutions if it is believed that doing so can reduce or mitigate the harm from the breach.
  • Jim Hester Wholesale Division Ltd. may disclose personal information without the knowledge or consent of the individual if:
    • The disclosure is made to the other organization, the government institution, or the part of a government institution, that was notified under the breach; and
    • The disclosure is made solely for the purpose of reducing the risk of harm to the individual that could result from the breach or mitigating that harm.

 

Privacy Policy (Client Files PIPEDA)

Intent

Jim Hester Wholesale Division Ltd. has adopted this Policy to ensure that all Jim Hester Wholesale Division Ltd. employees are aware of our commitment to the privacy and protection of client information.

Protecting the privacy and confidentiality of personal information is an important aspect of the way Jim Hester Wholesale Division Ltd. conducts its business. Collecting, using, and disclosing personal information in an appropriate, responsible, and ethical manner is fundamental to Jim Hester Wholesale Division Ltd.’s daily operations. 

Jim Hester Wholesale Division Ltd. strives to protect and respect the personal information of its customers, employees, business partners, and so on in accordance with all applicable regional and federal laws. Each staff member of Jim Hester Wholesale Division Ltd.  must abide by the organization’s procedures and practices when handling personal information.

Guidelines

Requirement of Confidentiality

In accordance with the Privacy Act and PIPEDA (Personal Information Protection and Electronic Documents Act), Jim Hester Wholesale Division Ltd. requires all employees to handle sensitive personal client information in a confidential and appropriate manner. It is understood that employees of Jim Hester Wholesale Division Ltd. will become aware of confidential information regarding our clients through the course of their employment. Employees agree that if confidential information is not effectively protected, the operations of Jim Hester Wholesale Division Ltd. may be threatened, and the well-being and privacy of our clients may suffer irreparably.

Employees of Jim Hester Wholesale Division Ltd. are required to keep all confidential information and relevant medical knowledge regarding both the Company and our clients confidential both during and after their term of employment. These practices have been adopted as they have been deemed essential to the protection of Jim Hester Wholesale Division Ltd., and the well-being and privacy of our clients.

Confidentiality Agreement

The following is classed as Confidential Information:

  • Client lists
  • Client medical histories
  • Client personal information
  • Medical research
  • Labour relations
  • Human resource planning, policies or procedures
  • Company financial information, status and statements
  • Any information, or documentation labelled “Confidential” by the Company, or listed as such by separate memorandum, or e-mail that informs of confidential status
  • Any information pertaining to (Jim Hester Wholesale Division Ltd.’s) clients, clients and visitors

 

Any information relating to the Company that is freely in the public domain may not be considered “Confidential”. In the event that an employee can prove that information was possessed before it was received from Jim Hester Wholesale Division Ltd., or that information was gained from an unrelated third party, said information will not be classified as “Confidential”.

Nondisclosure

In working for Jim Hester Wholesale Division Ltd., employees shall not divulge, disclose, provide or disseminate Confidential Information to any third party not employed by Jim Hester Wholesale Division Ltd. at any time, unless Jim Hester Wholesale Division Ltd. gives written authorization. Furthermore, Confidential Information shall not be used for any purpose other than its reasonable use in the normal performance of employment duties for Jim Hester Wholesale Division Ltd. 

Company Property

Upon termination of employment with Jim Hester Wholesale Division Ltd., employees shall promptly return (without duplicating or summarizing), any and all material pertaining to Jim Hester Wholesale Division Ltd. business in their possession including, but not limited to: all client information (charts, lists, etc.),physical property, documents, keys, electronic information storage media, manuals, letters, notes and reports. 

Legal

This agreement will not supersede any legal obligation to disseminate information when required to do so in a court of law.

 

Legal bases of our data processing (GDPR)

The processing of personal data can be based on different legal bases. If we need your data to fulfil a contract with you or to answer your queries regarding a contract, the legal basis for this data processing is i.a. Art. 6 (1) S. 1 lit. b GDPR. If we obtain your consent for certain data processing, the legal basis is i.a. Art. 6 (1) S. 1 lit. a GDPR. We carry out some data processing on the basis of our legitimate interest, whereby a balance is always made between your interests of protection and our legitimate interests. The legal basis for this is i.a. Art. 6 (1) lit. f GDPR. Insofar as processing is necessary to fulfil a legal obligation to which we are subject, the legal basis is i.a. Art. 6 (1) lit. c GDPR.

In the following, we explain how we process personal data via our website.

 

Cookies

Cookies are data that are stored on your computer by a website that you visit which enable reassignment to your browser. Cookies transmit information to the website that uses the cookie. Cookies can store various information, such as your language setting, the duration of your visit to our website or the information you have entered there. This avoids, for example, that you have to re-enter the required data each time you use our website. The information stored in cookies can also be used to identify preferences and align content according to areas of interest.

There are different types of cookies: session cookies are data that are only stored temporarily and deleted when you close your browser. Permanent or persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. With this type of cookie, the information can also be stored in text files on your computer. However, you can also delete these cookies at any time in your browser settings.

First-party cookies are set by the website you are visiting. Only this website can read information from these cookies. Third party cookies are not set by operators of the website that you are visiting. These cookies are used by marketing companies for example.

The legal basis for processing personal data using cookies and their storage duration may vary. If you have given us your consent, the legal basis is Art. 6 (1) lit.a GDPR. If data processing is carried out on the basis of our legitimate interests, the legal basis is Art. 6 (1) lit.f GDPR. The stated purpose then corresponds to our legitimate interest.

We use cookies to ensure the proper operation of our website, to provide basic functionalities, to measure the range and – with your consent – to tailor our services to preferred areas of interest.

You can delete cookies already stored on your device at any time. If you want to prevent the storage of cookies, you can change the settings in your Internet browser accordingly. Instructions for common browsers settings can be found here: Internet Explorer, Firefox, Google Chrome, Google Chrome mobile, Microsoft Edge, Safari, Safari mobile. Alternatively, you can install so-called ad blockers. Please note that some functions of our website may not work if you have deactivated the use of cookies.

When visiting our website, an information banner informs all vistors of our website about our use of cookies and refers to this privacy statement. As a vistor, you will be asked for your consent to the use of certain cookies, which are relevant in particular for the personalisation of services and for marketing measures. Once you have given your consent, you can revoke it at any time with effect for the future.

We use a number of tools to help us deliver our services: 

  1. Twitter Advertising (Retargeting or Conversion Tracking)

We use the services of Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. Within the EU/EEA, responsible for dealing with data subjects’ rights is

Twitter International Company
Attn: Data Protection Officer
One Cumberland Place, Fenian Street
Dublin 2, D02 AX07 IRELAND.

Twitter Ads allows advertisers to collect data from users who visit their website. Cookies and code are used to connect the website to another third-party platform such as Twitter. A non-reversible and non-personal hash value is generated from your usage data and transmitted to Twitter for analysis and marketing purposes. In addition, a so-called “Twitter pixel” can be used to track the actions of users after they have seen or clicked on a Twitter ad.

User behaviour, such as websites visited, content accessed, time of visit, etc., as well as device-related data, such as applications and operating systems used, are recorded. Your IP address is stored and used for the geographical control of advertising. With “cross-device personalization”, Twitter also tries to link all devices of a user. Since the data is stored and processed by Twitter, a connection to the respective user profile on twitter.com is also possible.

Anonymized data will be deleted within 6 months. Data that can possibly identify a specific user on Twitter will be deleted within 90 days. Further information on the duration of the storage can be obtained from the provider or at https://legal.twitter.com/ads-terms/international.html.

You can object to Twitter’s data collection by adjusting the settings in your Twitter account or at https://twitter.com/personalization. If you would like to opt out of interest-based advertising from certain third-party advertisers, you can do so at https://optout.aboutads.info.

For more information about the purpose and scope of the data collection and the further processing and use of the data, as well as the privacy settings, please refer to Twitter’s privacy policy: https://twitter.com/privacy.

 

  1. Twitter Analytics

We use “Twitter Analytics” on our website. Twitter Analytics stores and processes information about your user behavior on our website.

We use Twitter Analytics for marketing and optimization purposes, in particular to analyze the usage of our website and to be able to continuously improve individual functions and offers as well as the user experience. By statistically evaluating user behavior, we can improve our services and make it more interesting for you as a user.

 

  1. DoubleClick by Google

We use on our website the online marketing tool DoubleClick by Google. DoubleClick uses cookies to display ads that are relevant to users, to improve campaign performance reports, or to prevent users from seeing the same ads more than once. For this purpose, Google uses a cookie ID to track which ads appear in which browser. This prevents the same ad from being displayed more than once. In addition, DoubleClick can with the use of cookie IDs track so-called conversions in relation to ads. For example, if a user sees a DoubleClick ad and later visits the advertiser’s website with the same browser to buy something.

When you visit a page that uses DoubleClick and has the DoubleClick script enabled, your browser automatically connects directly to Google’s server. We as website operator, have no influence on the extent and further use of the data collected by Google through the use of this tool. We inform you according to our state of knowledge: By integrating DoubleClick Google receives the information that you visited certain parts of our website or clicked on an ad from us. If you’re registered with a service provided by Google, Google may connect the visit with your account. Even if you are not registered with Google or have not logged in, there is a chance that the provider will find out and store your IP address.

There are several ways how to prevent your data from being captured by this tracking procedure: (a) by changing your browser settings accordingly. Suppressing third party cookies means that you will not see any third-party ads. (b) By deactivating cookies for conversion tracking which will prevent interest-related advertisements from being displayed. To do this, you must block cookies from the domain “www.googleadservices.com” in your browser. (c) At https://www.google.de/settings/ads you can set an opt-out cookie. However, this setting will be deleted if you delete all your cookies. (d) By deactivating the interest-related ads of the providers that are part of the self-regulation campaign “About Ads” via the link http://www.aboutads.info/choices. This setting is deleted if you delete your cookies. (e) By permanently deactivating cookies in your browser settings: https://www.google.com/settings/ads/plugin. Please note that in this case you may not be able to use all functions of our website to their full extent.

Further information on DoubleClick by Google can be found at https://www.google.de/doubleclickand https://support.google.com/adsense/answer/2581949,
or in general: https://www.google.de/intl/de/policies/privacy. Alternatively you can visit the website of the Network Advertising Initiative (NAI) at https://www.networkadvertising.org.

 

  1. Google Ads (formerly Google AdWords), Remarketing and Conversion Tracking

We use the service Google Ads. Google Ads is an online advertising program of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

This means we display Google ads and use Google remarketing and conversion tracking. The ads are displayed on Google’s advertising network web pages in response to search queries. We also use Google ads remarketing lists for search ads. This allows us to customize search ad campaigns for users who have visited our website before. This service allows us to combine our ads with specific search terms or to display ads to previous visitors promoting our services. We may therefore display interest-based ads on other websites within the Google advertising network (as “Google ads” in Google search or on other sites) to users of our website.

For interest-related offers, an analysis of the online user behaviour is necessary. Google uses cookies to perform this analysis. Google sets a cookie on the user’s computer when the user clicks on an advertisement or visits our website. These cookies have a duration of 90 days. The information collected respectively is used to specifically target the visitor in a later search query. Further information on the cookie technology used can also be found in Google’s information on website statistics and in the data protection provisions. With this technology, Google and we receive information that a user clicked on an advertisement and was directed to our website. The information obtained from this is used exclusively for statistical evaluation to optimize the ad. We do not receive any information which allows us to identify a visitor. Your IP address is transmitted to Google, since we use Google’s IP masking on this website in the context of Google Analytics, your IP address is anonymised. The statistics provided to us by Google include the total number of users who clicked on one of our ads and, if applicable, whether they were forwarded to a page of our website with a conversion tag. These statistics enable us to track which keywords were particularly frequently entered and which ads lead to the user contacting us via the contact form.

You can find more information on data protection in the context of Google Ads at: https://policies.google.com/technologies/ads?hl=de

If you do not wish your data to be processed, you can prevent the cookies by changing your browser settings. In this case, your visit will not be included in the user statistics.

You also have the option of selecting the types of Google ads or deactivating interest-related ads on Google via the ad settings (https://adssettings.google.com/authenticated?hl=de). Alternatively, you can deactivate the use of cookies by third-party providers by using the deactivation help of the network advertising initiative.

However, we and Google continue to receive statistical information about how many users visited this site and when. If you also do not want to be included in these statistics, you can prevent this with the help of additional browser settings (e.g. the add-on Privacy Badger).

 

  1. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google LLC, (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Responsible authority for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Usage includes the operation mode Universal Analytics. This makes it possible to assign data, sessions and interactions across several devices to a pseudonymous user ID and thus to analyse the activities of a user across all devices.

Google Analytics uses cookies, which enable an analysis of the website usage. The information generated will generally be transmitted to and stored by Google on servers in the United States. However, within member states of the European Union or in other contracting states of the Agreement on the European Economic Area your IP address will be shortened by Google due to the activation of IP anonymisation on this website. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States, where it will be shortened accordingly.

The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. Google will use this information to evaluate your use of the website on our behalf, to compile reports on website activity and to provide other services related to website activity and internet usage. Our legitimate interest results from these purposes.
The data sent by us and linked to cookies or user IDs (e.g. user ID) are automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month.

The data sent and linked to cookies or user IDs will be automatically deleted after 14 months. Data whose retention period has expired is automatically deleted once a month.

You can prevent the use of cookies by changing your browser settings. Please note that you may not be able to use the full functionality of this website. In addition, you can prevent Google from collecting data generated by the cookie and related to your use of the website (including your IP address) by downloading and installing https://tools.google.com/dlpage/gaoptout?hl=de.

For more information about Google Analytics’ terms of use and Google’s privacy policy, please visit https://www.google.com/analytics/terms/de.html or https://policies.google.com/?hl=de.

 

  1. Google Re/Marketing Services

We use the marketing and remarketing services (“Google Marketing Services”) of the provider Google Ireland Limited (registration number: 368047), Gordon House, Barrow Street, Dublin 4, Ireland (“Google”) for the optimisation and economic operation of our online services.

Google Marketing Services allows us to better target advertisements for our website in order to present you only with advertisements that potentially match your interests. For example, if you see ads for our services on other websites, this is referred to as “remarketing”. For these purposes, when you visit a websites where Google marketing services are active, Google immediately runs a Google code and incorporates (re)marketing tags (invisible graphics or code, also known as “web beacons”) into the website. With their help, an individual cookie, i.e. a small file, is stored on your device (comparable technologies can be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com and googleadservices.com. It is recorded in this file which websites you visited, what content you are interested in and what offers you have clicked on and all technical information on the browser and operating system, referring websites, visiting times and other details of the use of the online offer. Your IP address is also recorded and shortened within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is it transmitted entirely to a Google server in the USA and shortened there. The IP address will not be combined with your data within other Google offers. The above information may also be linked by Google with such information from other sources. If you subsequently visit other websites, you may see ads

tailored to your interests, according to your interests.

We process your data within the Google marketing services framework pseudonymously. This means that Google does not store and process your name or e-mail address but processes the cookie-related data within pseudonymous user profiles. This information is transmitted to Google and stored on Google’s servers in the USA.

The Google marketing services we use includes the online advertising program “Google Ads” (formerly: “Google AdWords”). Within the usage of Google Ads, each ads customer receives a different “conversion cookie”. This means that cookies cannot be tracked via the websites of ads customers. The information obtained through this cookie is used to generate conversion statistics for ads customers who have opted for conversion tracking. Ads customers will know the total number of users who clicked on their ad and were directed to a conversion tracking tag page. However, they do not receive any information that personally identifies users.

 

  1. Google Tag Manager

For reasons of transparency we would like to point out that we use the Google Tag Manager of the provider Google 600 Amphitheatre Parkway, Mountain View, CA 94043, USA (650) 253-0000. The Google Tag Manager does not collect any personally identifiable information. The Google Tag Manager makes it easy for us to integrate and manage our tags. Tags are small pieces of code used, among other things, to measure traffic and visitor behavior, track the impact of online advertising and social channels, establish remarketing and targeting, and test and optimize websites. We use the Tag Manager for the Google Analytics service. If you have made a opt-out, the Google Tag Manager will take that opt-out into account. For more information about the Google Tag Manager, please visit: https://www.google.com/tagmanager/use-policy.html.

  1. Google Optimize

This website uses Google Optimize which is provided by Google 600 Amphitheatre Parkway, Mountain View, CA 94043, USA (650) 253-0000. This tool shows us which site experiences engage our website visitors and provides solutions to aid us in delivery of such.

  1. reCAPTHCA

This website uses reCAPTCHA on certain pages which is provided by Google 600 Amphitheatre Parkway, Mountain View, CA 94043, USA (650) 253-0000. This tool uses an advanced risk analysis engine and adaptive challenges to keep malicious software from engaging in abusive activities on our website. Meanwhile it permits legitimate users to login, make purchases, view pages or care accounts and fake users are blocked. The tool carries out an analysis in the background e.g. of the IP address to complete this function.

  1. Facebook

We offer you the opportunity to register and log in via your Facebook account. If you sign up via Facebook, Facebook will ask you for your permission to share certain information in your Facebook account with us. This may include your first name, last name, and email address to verify your identity and gender, as well as your general location, a link to your Facebook profile, your time zone, your date of birth, your profile picture, your “Like” information, and your friends list.

This information is collected by Facebook and transmitted to us in accordance with Facebook’s (https://ca.facebook.com/privacy/explanation) Privacy Policy. You can control the information we receive from Facebook through the privacy settings in your Facebook account.

This information is used to set up, provide and personalize your account.

If you sign up with us via Facebook, this registration will automatically be linked to your Facebook account and information about your activities on our websites may be shared on Facebook and published in your History and Friends News Feed.

 

  1. Custom Audiences (Facebook pixels)

We use the Audiances tool from Meta Platforms Ireland Limited (Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland)  as part of our on-demand online advertising. We use the Ad Manager to determine user target groups to display ads within the Facebook Network. Facebook selects users based on the profile information and other data provided. If a user clicks on an advertisement and then visits our website, Facebook receives information from the Facebook pixel embedded on our website that the user clicked on the advertising banner. In principle, a non-reversible and non-personal hash value is generated from your usage data and transmitted to Facebook for analysis and marketing purposes. Thereby a Facebook cookie is set which collects information about your activities on our website (e.g. surfing behaviour, subpages visited, etc.). In addition, your IP address is stored and used for the geographical control of advertising. We do not use Facebook Custom Audiences via the customer list or the “extended comparison” function.

Further information about the purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your setting options to protect your privacy can be found in Facebook’s privacy policy. You can make settings regarding which advertisements are displayed to you on Facebook under this link and in the Facebook account settings.

For more information about Facebook’s Custom Audiences service, please visit: https://www.facebook.com/business/help/744354708981227?id=2469097953376494

For more information on data processing and storage times, please contact the provider or visit https://www.facebook.com/about/privacy.

Deactivation of the “Facebook Custom Audiences” function is possible for logged in users at https://www.facebook.com/settings/?tab=ads#.

You can also prevent the storage of cookies by changing your browser settings. However, we would like to point out that in this case you may not be able to use all the functions of our website to their full extent. Further options for deactivating cookies by third-party providers can be found at www.networkadvertising.org/managing/opt_out.asp or on the Digital Advertising Alliance Opt-Out platform at http://optout.aboutads.info/?c=2&lang=en.

 

  1. LinkedIn Services

This website uses LinkedIn services to enhance the user experience on our website, to enable you to apply through LinkedIn, to facilitate the use of the LinkedIn social network and to contact other LinkedIn users. The provider is LinkedIn Ireland Unlimited Company, 70 Sir John Rogersons Quay, Dublin 2, D02R 296, Ireland.

LinkedIn receives information about your visits and interactions within the LinkedIn services we offer, e.g. when you sign up via LinkedIn or use plug-ins (e.g., “Share with LinkedIn” or “Apply with LinkedIn”). When using the LinkedIn services on our website, LinkedIn uses your login information, cookies, device information and Internet Protocol (“IP”) addresses to identify you and log your use. For more information about the cookies used by LinkedIn, please visit: https://www.linkedin.com/legal/cookie-policy.

If you are a member of the provider’s social network and are logged into the social network during your visit to this website, your data and information about your visit to this website may be linked to your social network profile. We do not have any influence on the extent of the data collected by the provider. For more information about the scope, nature, purpose, retention periods, and your rights and privacy preferences, please see the LinkedIn Privacy Notices at https://www.linkedin.com/legal/privacy-policy.

In cases where you expressly agree to the processing of your data, e.g. if you as a LinkedIn member agree to our request for access to your resources on LinkedIn, your consent is the legal basis for the data processing (Art. 7 GDPR). In other cases, e.g. if you apply to us via LinkedIn, the processing of your personal data is necessary for the establishment of the employment relationship (Art.6 (1) lit.b GDPR and § 26 BDSG).

To prevent LinkedIn from collecting data for advertising purposes, you can set a cookie via this link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
In addition, you can make further data protection adjustments via this link: https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences?lang=en

 

  1. LinkedIn Marketing Solutions

We use LinkedIn Marketing Solutions on our website. LinkedIn Marketing Solutions stores and processes information about your user behavior on our website.

We use LinkedIn Marketing Solutions for marketing and optimization purposes, in particular to analyze the use of our website and to be able to continuously improve individual functions and offers as well as the user experience.

Contact via e-mail or through the contact form

When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, your name and your telephone number) will be saved by us to answer your questions. If the use of our contact form requests further information that is not required to contact you, we have always marked it as optional. This information helps us to clarify your request and to improve the handling of your request. This information is expressly given on a voluntary basis and with your consent. Insofar as this information is about communication channels (e.g. e-mail address, phone number), you also agree that we may also contact you via this communication channel to answer your request. You can revoke this consent to communicate at any time by unsubscribing from our communications or submitting a deletion request directly to our Data Protection Officer, contact details for which can be found at the beginning of this policy. We delete the data collected in this context after storage is no longer necessary or restrict the processing if there are statutory retention requirements.

 

Newsletter

You can subscribe to our newsletter, which we use to inform you about our current offers. We use the so-called double opt-in procedure to register for our newsletter. This means that after you register, we will send you an email to the email address you have given, asking you to confirm that you would like to receive the newsletter. In addition, we store your IP address and time of registration and confirmation. The purpose of the procedure is to prove your registration and, if necessary, to clarify a possible misuse of your personal data. Mandatory information for sending the newsletter is your name and surname and your e-mail address. The provision of further, separately marked data is voluntary and is used to address you personally. After your confirmation, we will save your email address for the purpose of sending you the newsletter. You can revoke your consent at any time and unsubscribe from the newsletter by clicking on the link.

 

Third Parties

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, e.g. lead generation such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io; and

(ii) ShelfFlip, Inc., (trading as UserGems) headquartered at 2443 Fillmore St #380-3416, San Francisco, CA 94115, USA and can be contacted via privacy@usergems.com or by mail to the attention of the Privacy Officer at the address above.

 

What rights do you have in connection with the processing of your data?

Every data subject has the right of access (i.a. Article 15 GDPR), the right to rectification (i.a. Article 16 GDPR), the right to erasure (i.a. Article 17 GDPR), the right to restriction of processing (i.a. Article 18 GDPR), the right to object (i.a. Article 21 GDPR) and the right to data portability (i.a. Article 20 GDPR).

Right to object

What right do you have in the event of data processing for legitimate or public Interest?

Pursuant to i.a. Art. 21 para. 1 GDPR, you have the right to object at any time for reasons arising from your particular situation to the processing of your personal data on the basis of i.a. Art. 6 para.1 lit. e GDPR (data processing in the public interest) or i.a. Article 6 para. 1 lit. f GDPR (data processing to protect a legitimate interest), this also applies to profiling based on this provision.
In the event of your objection, we will no longer process your personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

Revocation of consent

You can revoke your consent to the processing of your personal data at any time. Please note that the revocation is only valid for the future.

Right to information

You may request information as to whether we have stored personal data about you. If you wish, we will inform you of the data concerned, the purposes for which the data is processed, to whom this data is disclosed, how long the data is stored and what further rights you are entitled to with regard to this data.

Further rights

In addition, you have the right to have your data corrected or deleted. If there is no reason for further storage, we will delete your data, otherwise we will restrict processing. You may also request that we provide all personal information that you have provided to us in a structured, current and machine-readable format either to you or to a person or company of your choice.

In addition, there is a right to lodge a complaint to the responsible data protection supervisory authority (Art. 77 GDPR).

Assertion of your rights

To exercise your rights, you can contact our Data Protection Officer using the contact details provided above.

 

Data Transmission

Your data will not be transferred to third parties unless we are legally obliged to do so, or data transfer is necessary to carry out the contractual relationship or you have given your prior express consent to the transfer of your data. We don´t sell your data.

When we use certain service providers, it may happen that your data is processed outside Canada. We are determined to transfer your data only when there is no equally suitable service in Canada. In the case that your data is transferred, we have communicated our requirements to protect our customer’s privacy and data. The provider is therefore obliged to ensure an adequate level of data privacy after the transmission.

Some services do not provide standard contractual clauses or other guarantees for a secure transmission. These services will only be used if you have given your prior consent to the transfer of the data to a non-secure third country within the meaning of Art. 49 para. 1 sentence 1a GDPR.