Types Of Information We Collect
The following provides examples of the type of information that we collect from you and how we use that information.
|Context||Types of Data||Primary Purpose for Collection and Use of Data|
|Account Registration||We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.||We have a legitimate interest in providing account related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history.|
|Client Information||We collect the name, and contact information, of our clients and their employees with whom we may interact.||We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.|
|Cookies and Third Party Tracking||We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our Website so that they can provide advertising about products and services tailored to your interests on our Website, or other websites.||Where required by law, we base the use of third party cookies upon consent.|
|Demographic Information||We collect personal information, such as your age or location.||We have a legitimate interest in understanding our users and providing tailored services.|
|Distance Information||When you use our Website we may collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location.||We have a legitimate interest in understanding our users and providing tailored services. In some contexts, our use is also based upon your consent to provide us with geo location information. This allows us to better estimate shipping times to enhance your experience.|
|Email Inter-connectivity||If you receive an email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.||We have a legitimate interest in understanding how you interact with our communications to you.|
|Feedback/Support||If you provide us feedback or contact us for support we will collect your name and email address, as well as any other content that you send to us, in order to reply.||We have a legitimate interest in receiving, and acting upon, your feedback or issues.|
|Mailing List||When you sign up for one of our mailing lists we collect your email address.||We disclose information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.|
|Mobile Devices||We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our Website.||We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.|
|Order Placement||We may collect your name, billing address, shipping address, e-mail address and phone number when you place an order.||We use your information to perform our contract to provide you with products or services.|
|Sweepstakes or contests||When you participate in a sweepstake or contest we collect information about you which includes contact information to notify you if you are selected.||We have a legitimate interest in operating the sweepstakes. In some contexts, we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws.|
|Website interactions||We use technology to monitor how you interact with our Website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.||We have a legitimate interest in understanding how you interact with our Website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.|
|Weblogs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our Websites. Among other things, it helps us understand which of our services is the most popular.|
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
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Use And Processing Of Information
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our Websites.
- To provide products and services or to process returns.
- To improve our services and product offerings.
- To streamline the checkout process.
- To conduct analytics.
- To respond to inquiries related to support or other requests.
- To send marketing and promotional materials including information relating to our products, services, sales, or promotions, or those of our business partners.
- For internal administrative purposes, as well as to manage our relationships.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete an online purchase we may collect your information to perform our contract with you, but we also collect your information because we have a legitimate interest in maintaining your information after your transaction is complete to efficiently respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under applicable laws, and/or our legitimate interest in conducting our business.
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Disclosure Of Information to Third Parties
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
- Affiliates and Acquisitions. We may disclose information to our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also disclose information to that company, including at the negotiation stage.
- Other Disclosures with Your Consent. We may ask if you would like us to disclose your information to other unaffiliated third parties who are not described elsewhere in this policy. You understand that any content that you post on our public forums on our Websites may be shared with third parties.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also disclose your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
- Service Providers. We may disclose your information to service providers. Among other things service providers may help us to administer our Website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
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What is a cookie?
A cookie is a small file placed onto your device that enables a variety of features and functionality. Cookies also enable you to easily share content and help us serve relevant ads to you. Cookies can do this because websites can read and write them, enabling websites to recognize you and remember important information that will make your use of a website more convenient (for example by remembering preference settings).
What types of cookies do we use?
We use a variety of cookie types:
- Preference Cookies. Preference cookies collect information about your choices and preferences, and allow us to remember language or other local settings and customize our Websites accordingly.
- Strictly Necessary Cookies. Strictly necessary cookies are necessary for the Website to work and to enable you to move around it and to use its features. Without these cookies, our Websites will not perform as intended and we may not be able to provide our Website or certain services or features you request.
- Analytics Cookies. Analytics cookies collect information about your use of our Websites and enable us to improve the way they work. For example, analytics cookies show us which are the most frequently visited pages on our Website, help us record any difficulties you have with our Website, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage, rather than the usage of a single person. This Website uses Google Analytics to collect information about you and your behaviors. If you would like to opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout/.
- Advertising Cookies. Advertising cookies are used for marketing purposes. This is discussed below in greater detail.
How are cookies used for advertising purposes?
Unless you clear these cookies from your browser, we may use this information to:
- Provide more relevant, interest-based advertising
- Provide aggregate reports of ads activity to advertisers and websites hosting the ads
- Help website and app owners understand how visitors engage with their sites or apps
- Detect and defend against fraud and other risks to protect users and partners
- Improve our products
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You can make the following choices regarding your personal information:
- Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we disclose with third parties or affiliates for direct marketing.
- Changes To Your Personal Information. We rely on you to update and correct your personal information. Most of our Websites, including the Project Portal, allow you to request that your personal information be changed. If our Website does not permit you to update or correct certain information, you can contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.
- Deletion Of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
- Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
- Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
- Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
Please address written requests and questions about your rights to firstname.lastname@example.org or RE: Data Privacy, Kele, Inc., 3300 Brother Blvd., Memphis, TN 38133. You may request a copy of the personal information that we hold about you, and exercise other rights as described above.
Note that, as required by law, we will require you to prove your identity. We may verify your identity by email or phone. Depending on your request, we will ask for information such as your name, the last item you purchased from us, the date of your last purchase from us, your account number, or your email address. We may also ask you to provide a signed declaration confirming your identity. Following a request and as required by applicable law, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
- A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
- If you are a business, proof that you are registered with the Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied.
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How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our Websites permit you to create an account, such as the Project Portal. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
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Other Important Information
The following additional information relates to our privacy practices:
- Transmission Of Information To Other Countries. As a multi-national company we transmit information between and among our affiliates. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
- Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
- Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
- Children. We do not knowingly collect personal information from children under the age of 13.
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If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
RE: Data Privacy,
Kele, Inc., 3300 Brother Blvd., Memphis, TN 38133
If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.
Effective Date: March 1, 2017
Last Update: 7/24/2022
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