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Privacy Policy

Privacy Policy 

Last Modified Date: April 24, 2023

 

ProSupplyDirect.com, (hereinafter, “ProSupplyDirect,” “we,” “our,” or “us”) provides online sales marketplace services (the “Services”) to sellers and purchasers of industrial tools and equipment (collectively, “you” or “your”) through its website, ProSupplyDirect.com (the “Site”).

 

This privacy policy (“Privacy Policy”) explains the types of information relating to an identified or identifiable natural person, or as otherwise defined under applicable Privacy Laws, (“Personal Data”) that we may collect from you when you use the Services or interact with the Site or any affiliated third-party website that may contain a link to this Privacy Policy. Unless explicitly stated otherwise, any current, updated, and new software and products, including the addition of new features and services shall be subject to this Privacy Policy, as well as our Terms of Use.  

 

If you are located in the European Economic Area (EEA), the United Kingdom (UK), or California or if the processing of your data is subject to the laws of a member state of the EEA, the UK, or to the laws of California, please carefully review the applicable EEA and UK Privacy Rights or California Privacy Rights section below for more information regarding your rights and our activities relating to your Personal Data. If the respective section is applicable to your information, then other sections in this Privacy Policy still may apply to you but are subject to (and considered modified by) that respective section.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data and how we will treat it. If you do not agree with our policies and practices, including our use and disclosure of your Personal Data, please do not use the Services and do not provide us with any Personal Data. However, if you choose to limit the information that you provide to us while using the Site and Services, you may not be able to use or participate in certain features of the Site and Services.

 

IMPORTANT: By clicking accept to this Privacy Policy or registering as a member to use the Services, you agree to the terms of this Privacy Policy and our Terms of Use, and consent to our privacy practices described in this Privacy Policy, including our use and disclosure of your Personal Data as described below.

 

REVISIONS AND MODIFICATIONS

Because our business needs may change over time, we reserve the right to modify this Privacy Policy. If at any time in the future we plan to use your Personal Data in a way that differs from this Privacy Policy, we will revise this Privacy Policy as appropriate. In the event of a material change to our Privacy Policy, we will notify you via email to the email address that you provided to us.  The date the Privacy Policy was last revised is identified at the top of this webpage as the “Last Modified Date.” Subsequently consenting and using the Services, constitutes your agreement to and acceptance of the Privacy Policy and its revisions and modifications. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Services and our Privacy Policy to check for any updates.

 

COLLECTION OF PERSONAL DATA

ProSupplyDirect collects different types of Personal Data about you while using the Services. We collect this Personal Data in various ways, including:

  • Directly from you when you provide it to us;
  • Automatically as you navigate through the Site; and
  • From third parties.

 

Personal Data Collected from You Directly

ProSupplyDirect may collect Personal Data directly from you when you use the Services. For example, when you register for an account, pay for the Software, or contact us. We collect the following types of Personal Data:

 

  • Identifiers, including name, telephone number, postal address, email address, financial and bank information, driver’s license number, social security number;

 

  • Information Listed in the California Customer Records Statute, including name, postal address, telephone number, social security number, driver’s license number, insurance policy number, employment information and history, financial and bank information;

 

  • Commercial Purchasing Data, including ledger data and payment history, record of applications and services utilized;

 

  • Employment Data, including employment status, income, and history;

 

  • Sensitive Personal Data, including social security number, driver’s license number.

 

Special Category Data

Some of the information that we may collect as a result of providing the Services is particularly sensitive (e.g., social security number and driver’s license number). We only collect this information as provided by or consented to by you.

Such sensitive information is only shared for the purpose of providing the Services you request or as consented for and will not be shared or used by us for any other purposes.

 

Personal Data Automatically Collected

ProSupplyDirect and third-party service providers may automatically collect information about you when you use the Site. This information is primarily needed to maintain the security and operation of the Site, and for our internal analytics so that we can improve our Services and Site. This information includes:

  • Identifiers, including IP address, cookies;

 

  • Internet or Other Electronic Network Activity Data, including (i) technical information collected in our logs (e.g., your IP address, page URLs and timestamp, etc.); and (ii) device information such as the mobile phone provider associated with the device you are using to access the Services, your device’s unique identifier, the type of device and its operating system, the pages or features accessed most frequently, calls and messages placed through the Services, how pages or features of the Services are used, search terms entered, and similar analytics about use of the Services; and

 

  • Location Data, we may collect, maintain, process, and use your location data, including the real-time geographic location of your mobile device (“Location Data”) as necessary to provide the Services’ full functionality.  By using or activating any location-based services on a mobile device, you agree and consent to our collection, maintenance, publishing, processing, and use of your Location Data in order to provide you with the Services.  We do not collect Location Data in a form that personally identifies you.  You may withdraw your consent to our use of your Location Data at any time by turning off the location-based services on the mobile device you are using, or by not using any location-based features.  Turning off or not using location-based features may impact the functionality of the Services as delivered to you.  Location Data provided by the Services is used for basic navigational purposes only, and is not intended to be relied upon in situations where precise location information is needed or where erroneous, inaccurate, or incomplete Location Data may lead to death, personal injury, property, or environmental damage.  Any use of real-time route guidance via the Services is at your sole risk.  You understand that Location Data provided by the Services may not be accurate.  We do not guarantee the availability, accuracy, completeness, reliability, or timeliness of Location Data displayed by the Services.

 

Cookies

To enhance your online experience with us, the Services may presently or in the future use “cookies.”  Cookies are text files that our web server may place on your hard disk to store your preferences.  Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us.  Once you choose to provide PII, however, this information may be linked to the data stored in a cookie.  You can set your browser to notify you when you receive a cookie, providing you with as much control as you wish as to the decision to accept/reject the cookie, and deletion of the cookie upon leaving our Services.  Please note, however, that if your browser does not accept cookies, you may not be able to take advantage of all of the features of our Services.  If you would like more information about cookies and how to control and delete cookies in various browsers, such as Internet Explorer, Firefox, Safari and Chrome, please visit https://aboutcookies.org/ and our Cookie Policy.

 

GIFs

We or our service providers may also use "pixel tags," "web beacons," "clear GIFs," “embedded links” and other commonly used information-gathering tools in connection with some pages of the Services and HTML-formatted email messages.  We use these tools for such purposes as compiling aggregate statistics about usage of the Services and response rates.  A pixel tag is an electronic image (often a single pixel), that is ordinarily not visible to website visitors, and may be associated with cookies on visitors’ hard drives. Pixel tags allow us and our Service Providers to count users who have visited certain pages of the Services, to deliver customized services, and to help determine the effectiveness of the Services. When used in HTML-formatted email messages, pixel tags can inform the sender of the email whether and when the email has been opened.

 

Clickstreams

As you use the Internet, you leave a trail of electronic information at each website you visit.  This information, which is sometimes referred to as "clickstream data”, can be collected and stored by a website's server.  Clickstream data can reveal the type of computer and browsing software you use and the Uniform Resource Locator (“URL”) or IP address of the website from which you linked to the Services. We may use clickstream data as a form of non-Personal Data to determine how much time visitors spend on each page of the Services, how visitors navigate through the Services, and how we may tailor our pages of the Services to better meet the needs of visitors.We will only use this information to improve the Services.

 

Personal Data Collected from Third Parties

In addition to collecting some Personal Data directly from you, we may collect Personal Data from third parties including our affiliates and subsidiaries, data providers, and credit agencies where permitted by law. You agree that the third-party providers of data, not ProSupplyDirect, are responsible for maintaining your information with proper and sufficient accuracy and authority in accordance with all governing laws and regulations. We make no effort to verify any information for any purpose, including accuracy, legality, or non-infringement that we properly receive from third parties.

We may also receive information about you from social media platforms, such as when you interact with us on those platforms or access our social media content.  Please note that the information we may receive from those third-party sites (such as Facebook, Instagram, Twitter and YouTube) is governed by the privacy settings, policies and/or procedures of the applicable platform, and we strongly encourage you to review them before submitting any information using a social media platform.

 

PROCESSING PURPOSES

We process your Personal Data for the following lawful business and commercial purposes, in accordance with the practices described in this Privacy Policy, and based upon the legal justifications set forth in the parenthetical:

  • Provide the Services. We may use your Personal Data to provide the Software, Services (including its full functionality), and any other products or services you may request from us. [CONSENT; CONTRACT; LEGITIMATE INTEREST]
  • Monitor the Services. We collect your Personal Data for monitoring purposes to help us diagnose problems with our servers, administer and troubleshoot the Services, calculate usage levels, analyze industry standards, and analyze transactions, trends, and statistics regarding the use of the Services. [CONSENT; LEGITIMATE INTEREST]
  • Respond to Inquiries and Fulfill Requests.  We may use your Personal Data to respond to your inquiries and to fulfill your requests for information.  This may include matching prospective sellers and purchasers with respect to available products. [CONSENT]
  • Create and Maintain User Account.  We use your Personal Data to create and maintain an account for you to engage in transactions and use the Services we make available. [CONSENT; LEGITIMATE INTEREST]
  • Communicate with You About the Services.  We may use your Personal Data to send you marketing information about new products or services and other items that may be of interest to you.  We may also contact you on behalf of our third-party business partners about a particular offering of theirs that may be of interest to you. [CONSENT; LEGITIMATE INTEREST]
  • Improve the Services.  We may use your information to make the Services more stable and user-friendly, to analyze service issues, improve the design and consent of the Services, personalize your experience, analyze how the Services are used, offer new products and services, and to develop new marketing programs relating to the Services. [CONSENT; LEGITIMATE INTEREST]
  • Send Administrative Emails.  We may use your Personal Data to send you email and text messages to: (a) confirm your account and your other Personal Data, (b) process transactions that you make using the Services, (c) provide you with information regarding the Services, or (d) inform you of changes to this Privacy Policy, our Terms of Use, or our other policies. [CONSENT; CONTRACT]
  • Support Business Operations. We may use your Personal Data to support our internal and business operations, including marketing, security, and advertising. [CONSENT; LEGITIMATE INTEREST]
  • Enforce Agreements. We may use your Personal Data to enforce separate agreements between you and us, enforce this Privacy Policy, our Terms of Use, or our third-party partner’s Terms of Use, or in connection with a transaction with a similar effect. [CONSENT; CONTRACT]
  • Fulfill Other Purposes. We may use your Personal Data to fulfill: (a) any other purpose for which you provide it; (b) any legal or regulatory requirements and any of our internal policies; (c) other purposes disclosed at the time of collection; (d) any other purpose with your consent; and (e) any other purposes set forth in this Privacy Policy. [CONSENT; LEGITIMATE INTEREST]

 

For Personal Data processed based only on your consent, you have the right to withdraw your consent at any time, subject to legal exceptions.

 

DISCLOSURE OF PERSONAL DATA

Except as otherwise described in this Privacy Policy, we will not sell, share, rent, or otherwise disclose your Personal Data that we collect from the Services to any third party for monetary or other valuable consideration, unless stated below or with your consent:

 

  • Parent Companies, Subsidiaries, and Affiliates. We may disclose Personal Data about you to our parent companies, subsidiaries, and affiliates.

 

  • Service Providers & Contractors. To help us provide superior service, your Personal Data may be shared with our service providers, contractors, and other third parties we use to support our business and who will safeguard it in accordance with this Privacy Policy. Such third parties may help us process payment information, identity verification, provide certain discounts, or provide customer service. These third parties are bound by contractual obligations to keep your Personal Data confidential and use it only for the purposes for which we disclose it to them. Without such information being made available, it would be difficult for you to purchase and use the Services, receive discounts from our third-party partners, provide us feedback to improve the Services, or access certain services, offers, and content on the Services.

 

  • Business Partners. We may share your Personal Data with our business partners to provide you with a product or service you have requested. We may also share your Personal Data to business partners with whom we jointly offer products, services, or programs.

 

  • Credit Agencies. We may share your Personal Data with credit agencies to conduct background checks and provide credit reports on merchants. We will not store (except than on a temporary basis) or use this information for any other purpose.

 

  • Advertising Partners. We may share your Personal Data with third party advertising partners, such as Facebook and Google Display Advertising and Remarketing services. These advertising partners may use first- and third-party cookies together to inform, optimize, and serve ads based on your past visits to the Site. You can opt out of these services using the Ads Preferences Manager or you can use the Google Analytics opt-out browser add-on. These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks, commonly referred to as “interest-based advertising.”

 

  • Authorized Representatives. If another individual is managing your account with us which the Services connect to on your behalf (for example, a wife managing the account of her husband), as authorized by you or as a personal representative under applicable law, that person can view all Personal Data about you on the Services.

 

  • In the Event of Merger, Sale, Divestitures, or Change of Control. ProSupplyDirect reserves the right to transfer Personal Data to a buyer or other successor in interest that acquires rights to that information as a result of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of ProSupplyDirect or substantially all of its assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about you is among the assets transferred.

 

  • With Your Consent. We may share your data for other purposes pursuant to your consent or at your direction.

 

  • Other Disclosures. We may disclose your Personal Data if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) conform to legal requirements and comply with any court order, law, or legal process, including responding to any government, law enforcement, or regulatory request; (ii) enforce the ProSupplyDirect Terms and Conditions, terms of our business partners, or other agreements, including between you and us, and any other documents included or referenced therein (all of which are incorporated into and made a part of this Privacy Policy by reference); (iii) fulfill the purpose for which you provide it; (iv) detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to our, your, or third parties’ rights, property, or safety.

 

Other than as set out above, you will receive notice when Personal Data about you might go to third parties, and you will have an opportunity to choose not to share the information.

 

ANONYMOUS AND AGGREGATE INFORMATION  

We may use data capture, analysis, and similar tools to extract, compile, synthesize and analyze non-Personal Data collected via your access and use of the Services (“Anonymous Data”).  We may further aggregate and combine your de-identified Anonymous Data (such as age, gender, race, religion, marital status, net worth, household income, the type of browser you are using, device type, the operating system you are using, and the domain name of your Internet service provider) with the Anonymous Data of others (“Aggregated Data”). To the extent that we collect any Anonymous Data or Aggregated Data, we shall own such Anonymous Data or Aggregated Data and may use it for any lawful business purpose without a duty to account for such use to you, provided that Anonymous Data is used only in an aggregated form, without specifically identifying the source of the Anonymous Data. Without assuming any obligations or liabilities of yours, we agree to use commercially reasonable efforts to comply with applicable laws and regulations respecting the dissemination and use such Anonymous Data or Aggregated Data. 

 

We may share de-identified and/or aggregate analytics with third-party partners about how you interact with the Site and Services, including usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Site and Services.

 

PUBLIC FORUMS

You may elect to share certain Personal Data with individuals (e.g., other members) or with the public via your chat rooms, profiles, message boards, social media, use of the Services, or any other public form (collectively, “Public Forums”). Be aware that when you choose to share information with friends, professionals, public officials, or with the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred. Any information you provide in Public Forums shall be deemed to be non-confidential, and as such, you will control such sharing via settings that we may provide. We shall be free to reproduce, use, disclose, and distribute any information posted in Public Forums. Always use caution when sharing information through the Services or any Public Forums. We cannot control the actions of the providers or the other users of any social media platform or Public Forum and cannot guarantee the privacy and safety of those areas; therefore, we are not responsible for any content or submissions contained on such Public Forums. You understand and agree that we are not responsible for any consequences of your sharing of information through and beyond the Services and any Public Forums linked to or contained on the Services.

 

THIRD PARTY WEBSITES

The Services may provide links to certain third-party websites, online services, mobile applications and/or contain advertisement from third parties that are not affiliated with us – and which may link to other website, services or applications. Please check the privacy policies and practices of those other third-party websites to learn how they collect, use, store and share information that you may submit to them or that they collect. We do not make any guarantee regarding those third-party website, services, or applications, and we are not liable for any loss or damage caused by the use of such websites. Any data collected by third parties is not covered by this Privacy Policy. This Privacy Policy only governs information collected on the Site or through the Services

 

CHOICES ABOUT YOUR PERSONAL DATA

 

Account Profile

After registering for an account within the Services, you may log-in to the account and edit your Personal Data in your profile.  

           

Cookies and Similar Technologies

You may stop or restrict the placement of cookies and similar technologies on your device or remove them by setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. For more information, please reference the Cookie Policy.

 

Marketing

The Services also provide you with checkboxes to "opt out" of data sharing activities or receipt of marketing communications from us or our affiliated third parties that you may have previously selected. We do not automatically add you to any marketing emails lists, but rather must obtain your consent via your “opt in” choices before doing so. You may have your name placed on our do-not-share list to specifically prohibit us from sharing your Personal Data with our business partners for marketing purposes.  For instructions on how you can further access your Personal Data that we have collected, or how to correct errors in such information, please contact us as specified in the Contact Information section below.

 

Advertising

We may use cookies and other technologies for purposes of online advertising. This means that when you use the Services, we or our advertising partners may use cookies that they collect or that we provide to them.  Such advertising partners may collect information about your use of the Services (including mobile applications) or your online activities over time and across different websites and devices. Collected information may include the content you viewed, the date and time that you viewed this content, and the website that referred you to the Services. This information may be associated with your unique browser, device identifier or IP address. Advertising partners may provide you with advertisements that you may see on the Services or on affiliated websites.To improve the relevancy and help measure the effectiveness of such advertisements, they may use cookies, web beacons, clear GIFs or similar technologies. These practices help tailor advertisements that are relevant and of use to you.  This Privacy Policy covers the use of cookies by us and does not cover the use of cookies by any advertisers. You may control or opt-out of such advertising by changing the cookie settings in your browser as described above.

We and our service providers may use information about your interactions with the Services to predict your interests and select the ads you see on and off the Services. This is known as interest-based advertising. We may also use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences and to determine what Services are most popular. We may also collect user data to enable “heat mapping” capabilities that track the areas of a webpage where users most frequently move the mouse or click. These tracking activities make it possible to monitor and analyze web traffic and evaluate user behavior to customize the Services.

Even though we do not disclose your Personal Data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. In providing interest-based ads, we follow the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance ("DAA"). We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

For more information about interest-based advertising and how you can opt out, visit:

    • Digital Advertising Alliance: http://www.aboutads.info/choices

 

    • Network Advertising Initiative: http://www.networkadvertising.org/choices/

 

Do-Not-Track

Many modern web browsers give you the option to send a “Do Not Track” (“DNT”) signal to the websites you visit, indicating that you do not wish to be tracked. However, there is currently no uniform standard for recognizing and implementing the DNT signals. At this time, the Services do not monitor nor specifically respond to DNT requests. If a standard is adopted that we must follow in the future, then we will inform you about that practice in a revised version of this Privacy Policy.

 

CONFIDENTIALITY & SECURITY

After receiving your Personal Data, we will store it on our systems for future use.  We have adequate physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our Service Providers' systems.

 

INTERNATIONAL TRANSFER OF PERSONAL DATA

The Services and data we receive from other sources are hosted in the United States and governed by United States law. Your Personal Data may be transferred to, and maintained on, computers located outside of your state, province/territory, or country where the privacy laws may not be as protective as those where you live. If you are using the Services from outside of the United States and choose to provide your Personal Data to us, you understand that your Personal Data will be transferred and processed in the United States. As a result, this Personal Data may be subject to access requests from governments, courts, law enforcement officials and national security authorities in the United States according to its laws. Subject to the applicable laws, we will use reasonable efforts to ensure that appropriate protections are in place to maintain protections on the Personal Data. By consenting to this Privacy Policy and using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of your Personal Data to the United States.

 

RETENTION OF PERSONAL DATA

ProSupplyDirect will retain your Personal Data for as long as reasonably required to fulfil the purpose(s) for which it was collected, comply with applicable laws, and for any legitimate and essential business purpose. When Personal Data is no longer needed or legally required, it will be permanently deleted or de-identified so that it can no longer be associated with a specific individual. We and our Service Providers will also delete your account information and Personal Data when you delete your account. Personal Data may remain in backups for a reasonable period of time), or as legally required. Otherwise, we store your Personal Data until you request us to remove it from our servers. We store our logs and other technical records indefinitely.

 

CHILDREN

ProSupplyDirect is not directed to children under the age of 18. We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws or rules for collecting Personal Data from minors. The Services will not knowingly accept Personal Data from anyone under 18 years old in violation of applicable laws, without consent of a parent or guardian.  In the event that we discover that a person under the age of 18 has provided Personal Data to us without parental consent, we will make efforts to delete the person’s information.  If you have concerns about this, wish to find out if your child has accessed the Services, or wish to remove your child's Personal Data from our servers, please contact us as specified in the Contact Information section below.

 

CALIFORNIA PRIVACY RIGHTS

This section explains how we collect, use, and disclose Personal Data about users, customers, and visitors who reside in California (“consumers” or “you”). It also explains certain rights afforded to consumers under California’s Shine the Light law and the California Consumer Privacy Act of 2018 (“CCPA”), as revised and updated by the California Privacy Rights Act (“CPRA”). This section uses certain terms that have the meaning given to them in the CCPA including Personal Data. “Personal Data” for purposes of this Privacy Policy has the same meaning as “Personal Information” by applicable California laws.

The following section does not apply to individuals who do not live in California on a permanent basis, individuals who do not collect Personal Data about, or individuals for whom all of the information we collect is exempt from California laws.

 

Categories of Personal Data Collected

We may collect (and have collected during the 12-month period prior to the “Last Modified” date of this Privacy Policy) the above categories of Personal Data about you in the Collection of Personal Data section above.

 

Purpose of Collection

We may use (and may have used during the 12-month period prior to the “Last Modified” date of this Privacy Policy) your Personal Data for the business or commercial purposes described in the Processing Purposes section above.

           

Sources of Personal Data

During the 12-month period prior to the “Last Modified Date” of this Privacy Policy, we may obtain (and may have obtained) Personal Data about you from the sources identified in the Collection of Personal Data section above.

           

Selling and Sharing Personal Data

We do not sell or share your Personal Data in exchange for monetary consideration. However, the definitions of Personal Data, ‘share,’ and ‘sale’ under CCPA are broad.

During the 12-month period prior to the “Last Modified Date” of this Privacy Policy, we may have shared or disclosed the following categories of Personal Data about you for a business or commercial purpose with certain categories of third parties, as described below:

 

Categories of Personal Data that May Be Sold, Shared, or Disclosed

Categories of Third Parties to whom Personal Data May Be Sold, Shared, or Disclosed

Business or Commercial Purpose of Selling, Sharing, or Disclosing Personal Data

Identifiers

  • Parent Companies, Subsidiaries, and Affiliates
  • Service Providers and Contractors
  • Regulatory Agencies and Insurance Companies
  • Business Partners
  • Advertising Partners
  • Referrals
  • Provide the Services
  • Communicate with You About the Services
  • Monitor the Services
  • Create and Maintain User Account
  • Respond to Inquiries and Fulfill Requests
  • Improve the Services
  • Enforce Agreements
  • Support Business Operations
  • Fulfill Other Purposes
 

Personal Data Categories Listed in The California Customer Records Statute (Cal. Civ. Code §1798.80(e))

  • Parent Companies, Subsidiaries, and Affiliates
  • Service Providers and Contractors
  • Credit Agencies
  • Business Partners
  • Advertising Partners
  • Provide the Services
  • Communicate with You About the Services
  • Monitor the Services
  • Create and Maintain User Account
  • Respond to Inquiries and Fulfill Requests
  • Improve the Services
  • Enforce Agreements
  • Support Business Operations
  • Fulfill Other Purposes
 

Protected Classifications under California or Federal Law

  • Parent Companies, Subsidiaries, and Affiliates
  • Service Providers and Contractors
  • Business Partners
  • Advertising Partners
  • Provide the Services
  • Communicate with You About the Services
  • Monitor the Services
  • Create and Maintain User Account
  • Respond to Inquiries and Fulfill Requests
  • Improve the Services
  • Enforce Agreements
  • Support Business Operations
  • Fulfill Other Purposes
 

Commercial Purchase Data

  • Parent Companies, Subsidiaries, and Affiliates
  • Service Providers and Contractors
  • Business Partners
  • Advertising Partners
  • Provide the Services
  • Monitor the Services
  • Improve the Services
  • Communicate with You About the Services
  • Support Business Operations
 

Internet or Other Electronic Network Activity Data

  • Parent Companies, Subsidiaries, and Affiliates
  • Service Providers and Contractors
  • Business Partners
  • Advertising Partners
  • Provide the Services
  • Monitor the Services
  • Improve the Services
  • Support Business Operations
  • Fulfill Other Purposes
 

Location Data

  • Parent Companies, Subsidiaries, and Affiliates
  • Service Providers and Contractors
  • Business Partners
  • Advertising Partners
  • Provide the Services
  • Monitor the Services
  • Improve the Services
  • Support Business Operations
  • Fulfill Other Purposes
 

Employment Data

  • Parent Companies, Subsidiaries, and Affiliates
  • Service Providers and Contractors
  • Credit Agencies
  • Business Partners
  • Provide the Services
  • Communicate with You About the Services
  • Monitor the Services
  • Create and Maintain User Account
  • Respond to Inquiries and Fulfill Requests
  • Improve the Services
  • Enforce Agreements
  • Support Business Operations
  • Fulfill Other Purposes
 

Sensitive Personal Data

  • Parent Companies, Subsidiaries, and Affiliates
  • Service Providers and Contractors
  • Credit Agencies
  • Business Partners
  • Provide the Services
  • Communicate with You About the Services
  • Monitor the Services
  • Create and Maintain User Account
  • Respond to Inquiries and Fulfill Requests
  • Improve the Services
  • Enforce Agreements
  • Support Business Operations
  • Fulfill Other Purposes
 

 

California Consumer Privacy Rights

Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Data, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the Contact Information section below with a reference to California Disclosure Information.

Under CCPA, consumers have certain rights regarding their Personal Data, as described below.

  • Right of Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:

 

  • The categories of Personal Data that we collected about you;

 

  • The categories of sources from which the Personal Data is collected;

 

  • The business or commercial purpose for collecting or selling Personal Data;

 

  • The categories of third parties with whom we share Personal Data;

 

  • The specific pieces of Personal Data that we have collected about you;

 

  • The categories of Personal Data that we disclosed about you for a business purpose or sold to third parties; and

 

  • For each category of Personal Data identified, the categories of third parties to whom the information was disclosed or sold.

 

  • Right of Deletion: You have the right to request that we delete any Personal Data about you which we have collected from you, subject to exceptions within the law.

 

  • Right to Opt-Out: You have the right to opt-out of the disclosure of Personal Data about you for monetary or other valuable consideration. However, we do not sell any Personal Data.

 

  • Right to Opt-In: We do not have actual knowledge that we collect, share, or sell the Personal Data of minors under the age of 18.

 

  • Right to Limit Use and Disclosure of Sensitive Personal Data: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Data that is collected or processed for “the purpose of inferring characteristics about a consumer.” However, we do not collect or process Sensitive Personal Data for this purpose.

 

  • Right to Correction: You have the right to request that we maintain accurate Personal Data about you and correct any Personal Data about you which we have collected from you, subject to exceptions within the law.

 

If you would like to exercise your California privacy rights, please refer to the Consumer Requests and Verification section below.

 

CONSUMER REQUESTS AND VERIFICATION

 

Right to Non-Discrimination

We may not discriminate against you because you exercise any of your rights under CCPA, including, but not limited to:

  • Denying goods or services to you;

 

  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

 

  • Providing a different level or quality of goods or services to you; or

 

  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Verifying Requests

You may request to exercise your California privacy rights or EEA and UK privacy rights by contacting us as described in the Contact Information section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request. If you request access to or deletion of your Personal Data, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address. When you make such a request, you can expect the following:

 

  • As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.

 

  • We will confirm that you want your information accessed, corrected, and/or deleted.

 

  • We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.

 

  • We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.

 

  • In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.

 

Authorized Agents

You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the Contact Information section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:

 

  • The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;

 

  • You to verify your identity directly with us; or

 

  • You to directly confirm with us that you provided the authorized agent permission to submit the request.           

 

 

CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy or our privacy practices, or would like to submit a consumer request please contact us using any of the below methods:

 

CCPA Request Form

 

help@prosupplydirect.com

 

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