Effective Date: May 29, 2019
- Subscriptions to our newsletters and other marketing messages;
- Invitations to and participation in our events;
- Recruitment processes;
- Customer/contractor and potential customer/contractor matters; and
- Procurement and potential procurement matters.
2. IDEAL AS DATA CONTROLLER
If no Entity has been clearly identified, the data controller or data controllers may be identified in the following order or precedence:
- For Personal Information that Jademar Lighting collects on or through its websites and mobile applications, the Entity that operates the website or mobile application is the data controller.
- For Personal Information that is collected in connection with our newsletters and other marketing message, the data controller is identified on the subscription form and in each message.
- For Personal Information collected in connection with invitations and participation in events, the data controller will be the Entity which is organizing such event as identified in the invitation.
- For Personal Information collected in the context of a recruitment process, the data controller is the Entity identified in the job posting or otherwise seeking to source a position.
- For Personal Information that Jademar Lighting collects pursuant to a customer or contractor relationship, the Jademar Lighting Entity with which you have the customer or contractor relationship is the data controller.
- For activities in the context of the procurement of products and services, the data controller will be the Entity identified in the order form, agreement, or similar document.
4. INFORMATION WE COLLECT
We (or our services providers on our behalf) may collect your Personal Information. “Personal Information” means information relating to an identified or identifiable natural person. For example, Personal Information may include:
- Contact Information (such as name, address, phone number or email address);
- Financial Information (such as credit card number or billing address);
- Demographic Information (such as gender, date of birth or zip/postal code);
- Recruitment Information (such as curriculum vitae/resume, work history, and qualifications);
- Location Information (such as the location of your device derived from GPS or WiFi use, the location of your IP address, or other information that indicates the current or prior location);
- Online Identifiers (such as IP address and device ID); and
- Any other information that you provide us that can be used to identify you.
We also may collect information about your use of the Online Services, such as your browser information, pages clicked, and time spent navigating the site. This information cannot be used to identify you. If we link this information with any Personal Information, we will treat such linked information as Personal Information.
We collect Personal Information from:
- Direct interactions with us, such as when you register with us, participate in our contests or surveys, interact with us at an event, purchase a product or service, or otherwise contact us;
- Through Social Media, such as if you link to social media platforms or use social media plug-ins, we may (depending on your user privacy settings on that social media platform) automatically receive information about you from that social media platform;
- Cookies and automated technologies, such as when you interact with our website, mobile applications or click on links on our emails;
- Mobile applications, such as when you use mobile applications that we may offer as part of our Online Services;
- Security systems, such as when you visit our offices we may obtain closed circuit television (“CCTV”) footage and other information through electronic means such as security/swipe card records. and
- From other sources such as business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies.
5. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
Below is a description of the Personal Information we collect, the likely source of the Personal Information, how we may use it, and for what purposes and pursuant to what legal basis.
|Use of your Personal Information||Categories of Personal Information we Process||Source of the Personal Information||Legal Basis|
|Register for a service||Contact Information and other information you provide, such as your topic preferences and areas of interest||You||Legitimate interests: To enable your registration|
Contract: As may be described on the registration page
|Obtain your subscription preferences and send eNewsletters and similar marketing communications||Contact Information and other information you provide, such as your topic preferences and areas of interest||You||Legitimate Interest: To provide you with information you need and other services you request and to efficiently communicate with you|
|Respond to inquiries and fulfill requests||Contact Information and other information you provide, such as your requests||You||Legitimate Interest: To provide you with information you need and other services you request and to efficiently communicate with you|
Consent: We will send you marketing communications by email and text/SMS pursuant to your consent
Contract: If you are a customer or prospective customer
|Fulfill purchases and other paid services||Contact Information, Financial Information, and other information you provide, such as your preferences or areas of interest||You||Contract: To maintain your order/purchase history to fulfill orders, ensure proper delivery, or provide other services related to your purchases.|
Note: We use a third party payment processor to collect and process your credit card information. We do not collect, access, store or process any credit card information related to your online transactions.
|Conduct surveys and questionnaires||Contact Information and other information you provide, such as your survey answers||You||Legitimate interests: To evaluate and take action with regard to your feedback and comments about our services|
Contract: If you are our customer or prospective customer
|Register for online and in person events and deliver event-related materials||Contact Information other information you provide, such as your preferences for the event||You||Legitimate interests: To enable your attendance at our events and to deliver you event materials|
Contract: As may be described on the registration page for the event
|Obtain current contact data and update contact records in our CRM||Contact Information and other information you provide, such as your relationships to people at Jademar Lighting||You and public sources, such as LinkedIn||Legitimate interests: To ensure the integrity of our customer and other contact data|
|Perform website analytics||Online Identifiers, Demographic Information, and other information we collect, such as interests, behavior tracking, event tracking||First and third party analytics cookies||Legitimate interests: To understand more about our website visitors (what pages you view, how long you visit, your devices, etc.) in order to improve our services|
|Deliver online advertising||Online Identifiers, Demographic Information, and other information we collect, such as interests, behavior tracking, event tracking||First and third party analytics cookies||Legitimate interests: To understand more about our website visitors in order to deliver relevant advertisements|
|Recruit personnel||Contact Information, Recruitment Information, and other information relevant to potential recruitment by Jademar Lighting, such as your resume, any cover letter/application, work history, qualifications, and reference information.||You, your references, your former employers, and public sources||Pre-contractual Measures: To recruit and evaluate potential candidates to join Jademar Lighting|
Legal obligations: To comply with applicable legal obligations, including in the field of employment law
Legitimate interest: To make the best recruitment decisions for our business
|Obtain and review security footage||Image||You||Legitimate interests: To ensure the security and safety of our facilities.|
If we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide us with the information when requested, we may not be able to perform the contract we have, or are trying to enter into, with you. We will inform you of any mandatory Personal Information we require from you and the consequences if you fail to provide it.
6. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY (ONLINE SERVICES)
Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and Internet activities. We use the following types of cookies on our Online Services:
- Session Cookies are used to operate our Online Services. Some cookies are essential for the operation of the Online Services. If a user chooses to disable cookies, certain content and features may not be available.
- Advertising Cookies are used to serve you with advertisements that we believe are relevant to you and your interests. These cookies also help us evaluate our marketing program performance and analytics.
- Security Cookies are used for general security purposes, such as user authentication and preventing fraudulent use or unauthorized access of data.
A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org. We refer to cookies, web beacons, and other similar technology as “Data Collection Technology.” Data Collection Technology enables us to remember your password for future log-ins, compile statistics about use of the Online Services, and detect and prevent fraud. Data Collection Technology also helps us and our ad management partners manage our online marketing program and deliver ads that are relevant or may be of interest to you.
Our policy on “Do Not Track” signals: California’s Online Privacy Protection Act requires website operators to disclose how they respond to web browser’s “Do Not Track” (“DNT”) signals. Some web browsers incorporate a DNT or similar feature that signals to websites that a user does not want to have his or her online activity tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Jademar Lighting, do not respond to DNT signals.
Interest-Based Advertising. Interest-based advertising is a way that helps companies provide you with more relevant advertising on the websites you visit of the applications you use. If you want to “opt out” of receiving online interest-based advertisements, please follow the instructions at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. An “opt-out” cookie will be placed on your device indicating that you do not want to receive interest-based advertisements. Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on the Online Services. It means that the online ads that you do see will not be based on your particular interests. If you delete cookies on your device, generally you will need to opt-out again. More information about online behavioral advertising can be found at www.aboutads.info.
7. HOW WE MAY SHARE YOUR PERSONAL INFORMATION
We may share Personal Information as follows:
- Service providers: Unless prohibited by applicable law, we may share Personal Information with our third-party service providers that help us operate our business, such as for website hosting, professional services, analytics, customer service, e-mail delivery and auditing. Such service providers must process the Personal Information we share with them only on our behalf and for the same purposes for which the Personal Information was collected. We will not sell or lease your Personal Information to any third parties for marketing purposes.
- Corporation transaction: Unless prohibited by applicable law, we may share, transfer or delete your Personal Information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Jademar Lighting or any affiliated company (in each case, whether in whole or in part). If required by applicable law, any such sharing of Personal Information will be reported to regulators in accordance with the applicable law.
8. THIRD-PARTY WEBSITES AND SERVICES
9. CHILDREN’S PRIVACY
Our services, including our Online Services, are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act and similar rules in other jurisdictions, if we learn that we have received any Personal Information directly from a child under age 16, or such other age as set by the laws of jurisdictions where we operate without his or her parent’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services and subsequently we will delete that Personal Information.
10. SECURITY OF YOUR PERSONAL INFORMATION
We implement appropriate technical and organizational measures designed to ensure your Personal Information in protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. For example, we limit access of your Personal Information to authorized parties, periodically inspect, assess, and evaluate the effectiveness of our technical and organizational measures designed to ensure the security of our processing, and limit our collection and use of your Personal Information to the extent necessary to provide you with our services.
Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of Personal Information. Any transmission is at your own risk and we request that you use appropriate security measures to protect your Personal Information. If you believe that Personal Information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
11. RETENTION OF PERSONAL INFORMATION
We will keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and all applicable legal requirements.
12. YOUR RIGHTS AND CHOICES
Opting out of our collection of your Location Information: If you do not want us to collect Location Information from your device, please delete our mobile application or disable your device’s location settings. Please note that disabling the location setting may affect certain features of the mobile application.
Maintaining the Accuracy of your Personal Information: We must ensure that your Personal Information is accurate and up to date. Please advise us of any changes to your Personal Information by contact using the information in the “How To Contact Us” section below.
Rights of Individuals in the European Economic Area: If you are located in the European Economic Area, you have the following rights with regard to your Personal Information:
- Right to access information about how we process your Personal Information, including the categories of Personal Information we process, recipients of your Personal Information, and purposes for our processing.
- Right to rectification of inaccurate Personal Information concerning you, as well as, taking into account the purposes of the processing, the right to have incomplete Personal Information completed.
- Right to erasure (deletion) of Personal Information concerning you where: (a) the Personal Information is no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) you withdraw your consent and there are no other legal grounds for the processing; (c) you exercise your right to object (see below) and there are no compelling legitimate grounds for the processing; (d) the Personal Information have been unlawfully processed; or (e) the Personal Information have to be erased for compliance with a legal obligation applicable to us.
- Right to restriction of processing (i.e., data will be blocked from normal processing but not erased) where: (a) you contest the accuracy of the Personal Information, for a period enabling us to verify the accuracy; (b) the processing is unlawful and you oppose the erasure of the Personal Information and requests the restriction of their use instead; (c) we no longer need the Personal Information for the purposes of the processing but they are required by you for the establishment, exercise or defense of legal claims; (d) you exercise your right to object (see below) pending the verification whether our legitimate grounds override those of you.
- Where processing is based on your consent, the right to withdraw consent at any time, without affecting the lawfulness of the processing prior to such withdrawal. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your Personal Information in some limited circumstances.
- Where processing is based on your consent, or on a contract, the right to data portability, i.e. the right to obtain a copy of the data concerning you in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from us.
- Right to object to the processing of Personal Information based on our legitimate interests, provided that there are no compelling legitimate grounds for the processing that would override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Please note that if you decide to exercise some of your rights, we may be unable to perform the actions necessary to achieve the purposes set out above or you may not be able to use or take full advantage of the services we offer.
13. INTERNATIONAL TRANSFER
14. HOW TO CONTACT US
12950 NW 25th Street, Suite 300
Miami, FL 33182 USA
By Email: [email protected]
You always have the right to lodge a complaint with your local competent supervisory authority or any authority that applies to Jademar Lighting.