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”).
REVISIONS AND MODIFICATIONS
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.
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.
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.
- 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]
- Support Business Operations. We may use your Personal Data to support our internal and business operations, including marketing, security, and advertising. [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
- Parent Companies, Subsidiaries, and Affiliates. We may disclose Personal Data about you to our parent companies, subsidiaries, and affiliates.
- 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 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.
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
CHOICES ABOUT YOUR PERSONAL DATA
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
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.
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/
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
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.
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
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
Purpose of Collection
Sources of Personal Data
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.
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
Personal Data Categories Listed in The California Customer Records Statute (Cal. Civ. Code §1798.80(e))
Protected Classifications under California or Federal Law
Commercial Purchase Data
Internet or Other Electronic Network Activity Data
Sensitive Personal Data
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.
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.
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.
CCPA Request Form
Copyright © ProSupplyDirect.com All rights reserved. The Services are protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Services, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.