Privacy Policy - NEW TABLE VERSION DRAFT

Privacy Policy

This website is operated by ProClip USA, LLC of 4915 Voges Rd., Madison, WI 53718 (USA) (hereinafter “Proclip,” “we,” or “us”). We respect your right to privacy, and this Privacy Policy describes how we collect, use, process, store and/or share any Personal Data that we collect from you.

We will collect the following Personal Data from you, and your Personal Data may be shared with the others noted below:

TYPE

DETAILS

LEGAL BASIS / PURPOSE OF COLLECTION

OTHERS WHO MAY RECEIVE YOUR PERSONAL DATA

Device Information

If this website’s cookies are accepted, Personal Data may be collected from you when using the website, including information regarding:

  • Your device browser, including your IP address and other information derived from cookies used on the Website.
  • Details of your visits to the Website, such as traffic data (e.g., the websites or search terms that brought you to the Website and the pages you view), location data, and the resources, advertisements and other websites that you access through the Website.
  • See the Cookies section below to learn how to remove cookies.

These Personal Data help us to determine whether and how our website is presented to you. It is necessary for the purpose of our legitimate interests to collect and process these Personal Data for the purposes of monitoring and improving website operation and enhancing your use of the Website.

When accepting cookies, your Personal Data may be shared with:

Google Analytics, which helps us understand how customers use our site. Google’s Privacy Policy can be reviewed at https://www.google.com/intl/en/policies/privacy/. You can also opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

Account Information

  • When ordering from this website, Personal Data may be collected from you to create a user profile. The user profile may include the following information (if provided by you):
  • Your name, company, shipping address, e-mail address, telephone number, and credit or debit card number.

These Personal Data allow us to fulfill your order. It is necessary for the purpose of our legitimate interests to collect and process these Personal Data to fulfill your order (including processing your payment information, arranging for shipping, and providing you with order confirmations, updates, and/or invoices); to screen for potential fraud or other impropriety; and when compatible with preferences you have shared with us, to provide you with information about our products.

When ordering, your Personal Data may be shared with:

  • Shopify, which is used to process and fulfill your order. Shopify’s Privacy Policy and Terms of Service can be reviewed at https://www.shopify.com/.
  • Netsuite, which is used to maintain our product inventory and sales data. Netsuite’s Privacy Policy and Terms of Service can be reviewed at https://www.netsuite.com/.

You can choose to provide us with the following Personal Data:

TYPE

DETAILS

LEGAL BASIS / PURPOSE OF COLLECTION

OTHERS WHO MAY RECEIVE YOUR PERSONAL DATA

Email Information

When you sign up for ProClip newsletters, you may choose to give us Personal Data such as your e-mail address.

These Personal Data allow us to send our newsletters to you, and it is necessary for the purpose of our legitimate interests to collect and process these Personal Data for these purposes.

When subscribing, your Personal Data may be shared with:

Klaviyo, which is used to initiate and execute your subscription. Klaviyo Privacy Policy and Terms of Service can be reviewed at:
https://www.klaviyo.com/legal/privacy/privacy-notice

Query Information

When you contact ProClip Support or otherwise submit questions, suggestions, or other comments to this website, you may choose to give us Personal Data such as your name, company, shipping address, e-mail address, telephone number, as well as any other Personal Data that you choose to provide.

These Personal Data help us to respond to, and/or otherwise act on, your comments, and it is necessary for the purpose of our legitimate interests to collect and process these Personal Data for these purposes.

When commenting, your Personal Data may be shared with:

Salesforce, which is used to notify us and prompt our action. Salesforce’s Privacy Policy and Terms of Service can be reviewed at https://salesforce.com/.

ProClip may share your Personal Data with other parties, such as:

  • Regulatory authorities and law enforcement agencies (where we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request);
  • External advisors, e.g. lawyers, accountants and auditors (as necessary to comply with any legal or regulatory obligation, and/or otherwise protect our legitimate interests).

Protection of Personal Data

We use Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our website. We also use layered firewalls and other security technologies to prevent unauthorized access. We also have other administrative, technical, and physical safeguards in place designed to protect the information collected from you. Access to Personal Data is limited to our employees who need access in order to carry out their job responsibilities.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will always do our best to protect your Personal Data, we cannot guarantee the security of any information you transmit to us, and any transmission is at your own risk.

Where We Keep Your Personal Data

We store your Personal Data on servers located in the United States. If your Personal Data is shared with others as described above, these others also have safeguards in place to protect your Personal Data.

How Long We Keep Your Personal Data

In general, we expect to keep your Personal Data from the date of collection for as long as is necessary for the purposes for which it was collected, or until you request deletion. In certain circumstances, we may hold your data for a longer period -- for example, if we are processing an ongoing claim, or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data.

When Personal Data is ready to be destroyed or disposed of, we will follow all applicable laws and regulations and take measures to ensure that all Personal Data held by us are destroyed and unrecoverable.

Accessing, Correcting, or Deleting Your Personal Data

You may request that your Personal Data be provided to you, revised, or removed by contacting privacy@proclipusa.com. If you are a ProClip client with a registered account, you may review and update your Account Information by logging into your account.

Cookies

As described above, we may store certain information on your computer using "cookies." A "cookie" is data stored on a user's computer which identifies your computer as it accesses our website, and which allows us to personalize your experience and monitor our website for performance issues. You can remove or block cookies using the settings in your web browser, but if you do so, our website may not appear or operate as intended.

Manage your cookie preferences here:
https://www.proclipusa.com/tools/data_preferences

Links / Other Websites

Our website may provide links to other websites (“Linked Websites“) for your convenience and information. Linked Websites are outside of our control, and are not covered by this Privacy Policy. We accept no liability in connection with any Linked Website, nor any contract entered into or through a Linked Website. If you have questions about how a Linked Website may use your information, please consult that website's privacy policy.

Your Rights Under the CCPA, GDPR And How To Exercise Them

Under the California Consumer Privacy Act (“CCPA”), you have a number of rights in relation to your Personal Data. In particular, these rights include the right to request the categories and Personal Data that were processed while carrying out our legitimate interests. We will only provide such information upon a verifiable consumer request, and in certain circumstances these rights might not be absolute.

Right to Know

You have a right to know what Personal Data is being collected by us, and the purposes for which the categories of Personal Data will be used.

You have the right to request a copy of the Personal Data held by us about you, and to access the following:

(1) The categories of Personal Data we have collected about you.

(2) The categories of sources from which the Personal Data is collected.

(3) The business or commercial purpose for collecting or selling the Personal Data.

(4) The categories of third parties with whom we share Personal Data.

(5) The specific pieces of Personal Data we have collected about you.

Right to Delete

You have the right to request that we delete your Personal Data, and direct any service providers to delete your Personal Data, except where maintaining your personal data is necessary to:

(1) Complete the transaction for which the Personal Data was collected; to fulfill the terms of a written warranty or product recall conducted in accordance with federal law; to provide you with a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship; or to perform a contract between us.

(2) Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

(3) Debug to identify and repair errors that impair existing intended functionality.

(4) Exercise free speech; ensure the right of another consumer to exercise that consumer’s right of free speech; or exercise another right provided for by law.

(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

(6) To enable solely internal uses that are reasonably aligned with your relationship with our business.

(7) Comply with a legal obligation.

(8) Otherwise use your Personal Data internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Opt-Out

You are able to direct a business that sells your Personal Data to stop selling that information. We do not sell any of your Personal Data or any customer data.

Right to Non-Discrimination

You have the right not to be discriminated against in terms of price for a service when you exercise a privacy right.

You can exercise any of these rights by submitting a request to privacy@proclipusa.com.

Your Rights Under the GDPR And How To Exercise Them

If you are an EU resident and the EU General Data Protection Regulation (“GDPR”) applies to you, you have a number of rights in relation to your Personal Data. In particular, these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. Note that in certain circumstances these rights might not be absolute.

Right

Further Information

Right to be Informed

You have the right to know whether your Personal Data is being processed by us, how we use your Personal Data, and your rights in relation to your Personal Data. 

Right of Access

You have the right to request a copy of the Personal Data held by us about you, and to access the following information in relation to the processing of your Personal Data:

(1) the purposes of processing;

(2) the categories of Personal Data concerned;

(3) the recipients of your Personal Data;

(4) the period for which your Personal Data will be stored;

(5) the existence of your right to lodge a complaint with the Office of the Data Protection Commissioner or appropriate official in your jurisdiction; and

(6) the source of your Personal Data.

We will only charge you for making such an access request where we feel your request is unjustified or excessive.

Right to Rectification

You have the right to request that we amend any inaccurate Personal Data that we have about you.

Right to Erasure

You have the right to ask us to erase your Personal Data where:

(1) it is no longer necessary to perform any contract between you and us;

(2) you withdraw your consent and there is no other legal basis permitting us to process your Personal Data;

(3) you object to the processing and we have no overriding legitimate grounds;

(4) your Personal Data have been unlawfully processed; or

(5) your Personal Data must be erased to comply with a legal obligation.

Please note that your Personal Data may be required to exercise some of this website’s functionality.

Right to Restriction of Processing

You have the right to ask us to restrict processing of your Personal Data in the following situations:

(1) where you contest the accuracy of your Personal Data;

(2) where the processing is unlawful and you do not want us to delete your Personal Data;

(3) where we no longer need your Personal Data for the purposes of processing but you require the data in relation to a legal claim; or

(4) where you have objected to us processing your Personal Data pending the verification as to whether or not our legitimate interests override your interests or in connection with legal proceedings.

When you exercise this right we may only store your Personal Data.

We may not further process the data unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or legal person or for reasons of important public interest.

Please note that it be may necessary for us to process some of your Personal Data in order to provide the Services, and in certain instances where you ask us not to process your Personal Data you may not be able to use the Services.

We will inform you before the processing restriction is lifted.

Right to Data Portability

You may request us to provide you with your Personal Data in a structured, commonly-used and machine-readable format and you may request us to transmit your Personal Data directly to another controller where this is technically feasible.

This right only arises where:

(1) we process your Personal Data on the legal bases of your consent or where it is necessary to perform our contract with you; and

(2) the processing is carried out by automated means.

Right to Object

You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.

You can opt out of such processing by contacting privacy@proclipusa.com.

Right to Object to Automated Decision-Making, including Profiling

You have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

We may not be able to comply with this request where the processing is necessary to enter or perform our contract with you or where you explicitly consent to this. However, you are entitled to have a person from our team review the decision so that you can query it and set out your point of view to us.

You can exercise any of these rights by submitting a request to privacy@proclipusa.com. We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay, and at the latest within one month of receiving your request. We may extend this up to 2 months if necessary, however we will inform you if this arises.

You also have the right to lodge a complaint about the way we handle or process your personal data with your national data protection authority.

Users Under Age 13

Our website is not directed to, or for use by, users under the age of 13.

Changes To This Privacy Policy

If any changes are made to this Privacy Policy, the changes will be posted on this webpage, and you will be notified via email, and/or when you access this website. You may be required to read and accept the Privacy Policy to continue use of this website. 

Privacy Questions?

Please contact us at privacy@proclipusa.com with any questions, requests, or comments regarding our privacy practices.

 
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