PERSONAL IDENTIFICATION INFORMATION
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, place an order, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, mailing address, phone number. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
NON-PERSONAL IDENTIFICATION INFORMATION
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
WEB BROWSER COOKIES
HOW WE USE COLLECTED INFORMATION
PeopleDelight may collect and use Users personal information for the following purposes, and generally related to sales and marketing purposes:
– To improve customer service
Information you provide helps us respond to your customer service requests and support needs more efficiently.
– To personalize user experience
We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
– To improve our Site
We may use feedback you provide to improve our products and services.
– To process payments
We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.
– To send periodic emails
We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.
HOW WE PROTECT YOUR INFORMATION
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Sensitive and private data exchange between the Site and its Users happens over a TLS secured communication channel and is encrypted and protected with digital signatures.
SHARING YOUR PERSONAL INFORMATION
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
THIRD PARTY WEBSITES
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
YOUR ACCEPTANCE OF THESE TERMS
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
1324 Modoc Avenue
Menlo Park, CA 94025
EU-US PRIVACY SHIELD INFORMATION
This EU-US Privacy Shield Policy (the “Policy”) applies to all personal information received by PeopleDelight in the United States from the EEA, in any format, including electronic, paper or verbal.
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for PeopleDelight or to which PeopleDelight discloses personal information for use on PeopleDelight’ behalf.
“PeopleDelight” means PeopleDelight Inc, its predecessors, successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of PeopleDelight or its clients to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, PeopleDelight will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy have been developed based on the EU-US Privacy Shield Principles.
NOTICE: Where PeopleDelight collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which PeopleDelight discloses that information, the choices and means, if any, PeopleDelight offers individuals for limiting the use and disclosure of personal information about them, and how to contact PeopleDelight. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to PeopleDelight, or as soon as practicable thereafter, and in any event before PeopleDelight uses or discloses the information for a purpose other than that for which it was originally collected.
Where PeopleDelight receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
CHOICE: PeopleDelight will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, PeopleDelight will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. PeopleDelight will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY AND PURPOSE LIMITATION: PeopleDelight will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. PeopleDelight will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
ACCOUNTABILITY FOR ONWARD TRANSFER: PeopleDelight will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Shield Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where PeopleDelight has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, PeopleDelight will take reasonable steps to prevent or stop the use or disclosure. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, PeopleDelight is potentially liable.
ACCESS AND CORRECTION: Upon request, PeopleDelight will grant individuals reasonable access to personal information that it holds about them. In addition, PeopleDelight will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Individuals have a right to access their information, and can contact PeopleDelight at the mailing address or email address listed below in order to obtain their information.
SECURITY: PeopleDelight will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
RECOURSE, ENFORCEMENT AND LIABILITY: PeopleDelight will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy, and to assess potential liability in cases of onward transfer to third parties. Any employee that PeopleDelight determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment. In compliance with the EU-US Privacy Shield Principles,
1324 Modoc Avenue
Menlo Park, CA 94025
PeopleDelight has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
The U.S. Federal Trade Commission (FTC) is the enforcement authority which has jurisdiction over PeopleDelight’s compliance with Privacy Shield, and PeopleDelight is subject to the investigatory and enforcement powers of the FTC. Please note that if your complaint is not resolved through these channels, PeopleDelight acknowledges the possibility, under certain limited conditions, for individuals to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by PeopleDelight to these Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation. PeopleDelight also acknowledges that it may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
US-SWISS SAFE HARBOR
1324 Modoc Avenue
Menlo Park, CA 94025
PeopleDelight has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visitwww.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
Questions or comments regarding this Policy should be submitted to the PeopleDelight Privacy Office by mail to:
1324 Modoc Avenue
Menlo Park, CA 94025
Or by e-mail to Fernando Pizarro at contact@PeopleDelight.com
This document was last updated on February 3, 2017.