- Categories of Information We Collect
- Sources of Personal Information
- Use And Processing of Information
- Disclosure of Information to Third Parties
- Cookie and Similar Tracking Technologies
- Your Choices and Rights
- Opt Out of the “Sale” or “Sharing” of Personal Information
- How We Protect Your Information
- How We Retain Your Information
- Transfers Of Information To Other Countries
- Children’s Policy
- Third Parties And Links To Other Websites And Services
- Commercially Recognized Opt Out Signal
Categories 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.|
|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.|
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Sources Of Personal Information
We collect your personal information in the following ways, pursuant to applicable law:
Directly From You, when you use our Services, register for an account, contact us, respond to a survey, sign up to receive emails, text messages, and/or postal mailings.
From Our Third Party Partners, including from third parties that we have partnered with to provide you the Services that you have requested from us.
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Use And Processing Of Information
We use your personal information for the following business purposes (“Processing Purposes”) associated with our general business operations. We may collect your personal information:
- 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.
- To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
- To detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of Kele and our users, customers, employees, or others.
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.
Legal Basis of Processing
- With Your Consent: In certain instances, we ask for your consent to process your Personal Information for specific purposes. Provision of your consent is voluntary, and you have the right to withdraw your consent at any time.
- To Perform a Contract With You: We will process your personal information when processing of your personal information is necessary for the evaluation, execution or performance of a contract with you.
- When We Have Legal Obligations: We will process your personal information when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable government request, including law enforcement.
In some cases, your provision of personal information may be required by a statutory or contractual obligation.
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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.
- Social Media Platforms and Networks. Some of our websites have features such as, plugins, widgets, or and other tools made available by third parties that may result in information being collected or shared between us and the third party. The third party’s use of your information is not governed by this Policy. You may have the right to opt out of our use of these technologies, as further described in this Policy.
- Business Transaction. We may disclose personal information to a potential or actual buyer in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), including any due diligence related to such a transaction.
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Cookie and Similar Tracking Technologies
We differentiate between cookies that are essential for the technical features of the Services and optional analytics and advertising cookies.
|Essential Cookies||These are cookies that the Services need in order to function, and that enable you to move around and use the Services and features. Without these essential cookies, the Services will not perform as smoothly for you as we would like them to and we may not be able to provide the Services or certain services or features you request. Examples of where these cookies are used include to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.|
|Analytics Cookies||Analytics cookies allow us to understand more about how many visitors we have to our Services, how many times they visit us, and how many times a user viewed specific pages within our Services. Although analytics cookies allow us to gather specific information about the pages that you visit and whether you have visited our Services multiple times, we cannot use them to find out details such as your name or address. We use Google Analytics. For more information about Google Analytics, please refer to “How Google Uses Information From Sites or Apps that Use Our Services,” which can be found at https://policies.google.com/technologies/partner-sites, or any other URL Google may provide from time to time.|
Depending on your location and applicable laws, we may give you the option of adjusting your preferences with regard to the categories of cookies we use. When this option is available, you can configure your personal settings on our Cookies Banner under “Cookie Preferences” or via other options that may be available on the relevant Service. If you use a different device to access the same Services, you may need to manage your settings for each separate device you use.
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You may have certain rights regarding your personal information. The rights available to you depend on our reason for processing your personal information and the requirements under applicable law (i.e., your rights will vary depending on whether you are located in, for example, California, European Union, and United Kingdom). Specifically, you may have the following rights:
- Access: You have the right to request access to the personal information we hold about you, along with other information such as the purposes of the processing, the recipients or categories of recipients to whom the personal information has been or will be disclosed, the sources of the personal information, retention, and transfers of personal information.
- Correction: You have the right to request correction of inaccurate personal information we have about you. Depending on the purposes of the processing, you may have the right to have incomplete personal information completed, including by means of providing a supplementary statement. You may also be able to correct your information in your account or profile.
- Deletion: You have the right to request that we delete your personal information.
- Data Portability: Under certain circumstances, you have the right to receive the personal information about you that you have provided to us, in a structured, commonly used, and machine-readable format.
- Restriction of Processing: You have the right to request that we restrict the processing of your personal information in certain cases. Where applicable, the respective personal information will be marked accordingly and may only be processed by us for certain purposes.
- Objection to Processing: In certain circumstances, you have the right to object to our processing of your personal information.
- The following categories of personal information disclosed are considered “sale”/ “sharing” under California law: information collected by cookies, demographic information, and distance information.
- The following categories of third parties to whom personal information was disclosed are considered “sale”/ “sharing” under California law: social media platforms and networks.
- Right to Opt Out of our Use of your Sensitive Personal Information (in certain instances and if permissible under applicable law). You have the right to request the restriction of processing of your sensitive personal information. At the current time, however, we do not collect or disclose sensitive personal information.
Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law. In some cases, we may limit or deny your requests to access or delete your information. This may occur because the law permits or requires us to do so, or if we are unable to adequately verify your identity.
Please address written requests and questions about your rights to email@example.com 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.
Depending on where you are located, you may have the right to lodge a complaint with the relevant supervisory authority.
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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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How Long We Retain Your Information
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Transfers of Information to Other Countries
We are based in the United States. If you are located outside of the United States, you should be aware that your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including the United States, and the laws may be less stringent than the laws in your country. Where required by applicable law, we will provide appropriate protections for personal information transferred to the United States, including by implementing appropriate contractual controls.
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We do not knowingly collect personal information from children under the age of 13.
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Third Parties And Links To Other Websites And Services
Our websites and Services may contain links to websites, content, or services owned or operated by third parties. Please note, we have no control over the privacy practices of websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or disclosed.
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Commercially Recognized Opt Out Signal
Kele generally recognizes commercially recognized opt-out preference signals (e.g., Global Privacy Controls). Recognition of this signal applies only to the specific device and/or browser that communicates the signal and does not cross over to all devices/browsers you use to access the Services.
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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
Effective Date: March 1, 2017
Last Update: 1/27/2023
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