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Effective Date / Last Updated September 3, 2024

Introduction

Jostens, Inc. and its corporate affiliates (“Jostens,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use, share, and safeguard your information. This Privacy Policy applies to individuals who access this website, our mobile applications, widgets, and interactive properties (collectively, “Sites”) and any of our online and, where required, offline services (collectively, “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. If we make material changes to our Privacy Policy, we may also notify you by other means, such as sending an email or posting a notice on our home page. If required by applicable data protection laws, we will obtain your consent to any material changes. Please review this Privacy Policy periodically.

Please also refer to our Terms of Use regarding the proper usage of the Sites and Services. For more information as to our use of cookies and other tracking technologies, please see our Cookie Policy.

This Privacy Policy covers the following topics:

  1. What is Jostens?
  2. Personal Data We Collect
  3. How We Use Your Personal Data
  4. How We Share Your Personal Data
  5. Universal Opt-Out Mechanisms
  6. International Data Transfers
  7. Security
  8. Third Party Links
  9. Children’s Privacy
  10. Your State Privacy Rights and Additional Disclosures
  11. Accessibility
  12. How to Contact Us
  13. Notice to California Residents
  14. Europe and the United Kingdom

 

1. What is Jostens?

As the most trusted partner in celebrating moments that matter, the essence of our mission is conveyed with three simple words: Capture. Celebrate. Inspire. It’s all about recognizing life’s most important moments and inspiring the creation and celebration of even more. Commemorating milestones takes many forms. Whether it’s the custom graduation announcements that spread the news to loved ones far and wide, that perfectly-framed diploma radiating with pride, or the tassel hanging from your rearview mirror, we honor the stories written by you. These are your moments that matter.

Our offices are located at 7760 France Avenue South, Suite 400, Minneapolis, MN 55435, United States of America. Jostens is the data controller of all personal data collected from residents of the European Economic Area and the United Kingdom.

2. Personal Data We Collect

We collect personal data from you through your use of the Sites and Services. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual. We collect the following types of personal data:

Personal Data You Provide

Depending on how you interact with our Sites and Services, we will collect the following personal data that you voluntarily provide to us for the following purposes:

  • Create an Account. To create an account, you will provide us with your name, email address, and you will create a password for future login purposes.
  • Purchase Products. When you purchase a product, you will provide us with your name, school information, email address, physical address, phone number, and payment information. Depending on the product, you may also provide us with your age, gender, height, weight, clothing size, and ring size. We use this information to manufacture, customize, and print the products you purchase and to process and deliver your products.
  • Check Order Status. To check your order status, you will provide us with your email address, telephone number, and order number.
  • Subscribe to Our Newsletter. To subscribe to our newsletter, you will provide us with your email address.
  • Submit User Content. For certain personalized products, you may submit user content such as school information, photographs, video recordings, signatures, and audiovisual materials, and any additional information you choose to provide us with.
  • Renaissance Sign Up. To sign up to be part of a Renaissance Region, you will provide us with your name, email address, and school information.
  • Warranties. To submit a warranty claim, you will provide us with your name, email address, phone number, physical address, school information, and any additional information you choose to provide us with.
  • Request a Quote or Sample. To request a quote or sample, you will provide us with your name, phone number, email address, physical address, school information, and any other information you choose to provide us with.
  • Register for Events. To register for events, you will provide us with your name, email address, school information, and any other information you choose to provide with us.
  • Contests and Sweepstakes. If you enter a contest or sweepstakes we offer, you will provide us with name, physical address, email address, and any other information required in the entry form of the entrant and, if applicable, the entrant’s legal guardian(s).
  • Careers. If you apply for a job with us through the Sites, you will provide us with your name, email address, telephone number, physical address, employment history, education history, social media handle information, and any other information you choose to provide in your resume or cover letter. You may also choose to provide us with your gender, ethnicity/race, veteran status, and disability status. You may choose to apply for a job with us through Indeed or LinkedIn. Please review Indeed’s privacy policy for more information hereand LinkedIn’s privacy policy for more information here.
  • Communicate with You Via Email or Phone. We may collect and use your contact information such as when you contact our customer service representatives, sales associates, or independent sales representatives through email or phone. We may use this information to provide support, contact you regarding our products and Services that we feel may be of interest to you and to inform you of any changes to our Sites and Services. If you wish to unsubscribe from our marketing emails, click “unsubscribe” in the email footer or email us at remove@jostens.com. Please note that our customers and partners (such as schools and independent sales representatives) may also send you marketing communications regarding Jostens products unless you unsubscribe from their communications.
  • Communicate with You Via Text. If we communicate with you via text, we will collect your telephone number and any information you provide in the text message.
  • Chat Feature. If you use our Live Chat Feature (aka, Jostens Support Chat), we will collect the personal data you choose to provide in your message. Our Live Chat Feature is provided by Salesforce. Salesforce may collect, record, and store the information you provide in the chat. Please review Salesforce’s privacy policy here.

Personal Data as You Navigate Our Sites

We automatically collect certain personal data through your use of our Sites and our use of cookies and other tracking technologies, such as the following:

  • Usage Information. For example, the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
  • Device Information. For example, hardware model, operating system, application version number, and browser.
  • Mobile Device Information. Aggregated information about whether the Sites are accessed via a mobile device or tablet, the device type, and the carrier.
  • Location Information. Location information from Site visitors on a city-regional basis.

To learn more about how we use cookies and to manage your cookie settings, please see our Cookie Policy.

Personal Data We Collect About You from Other Sources

In some cases, we may receive cookie information, contact information, and education information about you from other sources. These sources include partners, customers, social networks, advertising networks, marketing partners, and publicly available databases. Subject to applicable legal and contractual requirements, we use this information to advertise to you, to provide our products and Services to you, and to obtain information about how you are using our Sites and Services. If you sign in with your Google account to provide us with content, Google will share your contact information and the photographs you choose to provide us with.

Personal Data Received from Schools

We also may collect personal data about you from or on behalf of our school customers (e.g., name and class year). We use personal data about you that we receive from or on behalf of our school customers to create and promote products and Services for the benefit of the school, to customize products as requested by purchasers, and for other purposes permitted under this Privacy Policy except as prohibited by applicable law and except to the extent the providing party or data subject (i.e., you) has restricted our rights to use such personal data. We will not sell or rent personal data provided by schools to any third party.

3. How We Use Your Personal Data

In addition to the purposes stated above, we may use all the personal data we collect in accordance with applicable law such as to:

  • Maintain and improve our Sites and Services;
  • Protect the security and integrity of our Sites and Services;
  • Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use, and to otherwise fulfill our legal obligations;
  • Monitor compliance with and enforce this Privacy Policy and any applicable agreements and policies;
  • Defend our legal rights and the rights of others;
  • Fulfill any other purposes for which you provide it;
  • For any purpose that is reasonably necessary to or compatible with the original purpose for which we collected the personal data as disclosed to you; and
  • Comply with applicable law.

4. How We Share Your Personal Data

We may share the personal data that we collect about you in the following ways:

  • With vendors who perform Site-related services on our behalf (e.g., advertising and marketing providers, customer relationship management platforms, social media platforms, payment processors, product delivery providers);
  • To the extent that we are required to do so by law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;
  • With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
  • With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
  • With any other person or entity where you consent to the disclosure; and
  • For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.

The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

For more information on how we sell personal data to third parties, see our “Your State Privacy Rights” section below.

5. Universal Opt-Out Mechanisms

Our Sites recognize the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our Sites do not currently interpret, respond to, or alter their practices when they receive “Do Not Track” signals.

6. International Data Transfers

We operate internationally and transfer information to the United States for the purposes described in this policy. The United States may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. Your personal data can be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States.

For any transfers of personal data from the European Economic Area (EEA), Switzerland or the United Kingdom that we make to other entities as described in this Privacy Policy, we use appropriate safeguards to ensure for the lawful processing and transfer of the personal data, including, when appropriate, the use of standard contractual clauses approved by the European Commission and/or United Kingdom’s international data transfer agreement. To obtain a copy of the safeguards, contact us at privacy@jostens.com.

7. Security

We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

8. Third Party Links

The Sites may contain links that will let you leave the Sites and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.

9. Children’s Privacy

The Sites and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal data from children under 13.

10. Your State Privacy Rights and Additional Disclosures

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. If you are a California resident, please see our “NOTICE TO CALIFORNIA RESIDENTS” section below. For other state residents, your privacy rights may include (if applicable):

  • The right to confirm whether or not we are processing your personal data and to access such personal data and the categories of personal data we are processing or have processed;
  • The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
  • The right, at our option, to obtain a list of specific third parties, other than natural persons, to which we have disclosed your personal data or any personal data;
  • The right to obtain a list of categories of third parties to which we have disclosed your personal data;
  • The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
  • The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
  • The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
  • The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

Depending on how the applicable privacy law defines a “sale,” we may sell personal data to third parties. For instance, if you are a resident of Colorado or Connecticut, our use of cookies and tracking technologies constitutes a sale of personal data to third-party advertisers. We also use cookies and other tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. We do not use personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.

To exercise your rights, please submit a request through our interactive webform available here or by calling us at 1-855-314-8390. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision through our interactive webform available here or by calling us at 1-855-314-8390. If you would like to opt out of targeted advertising, you may alter your cookie preferences by clicking Your Privacy Choices in our site footer.

11. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below. Please also see our Accessibility Statement available here.

12. How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email us at privacy@jostens.com, call us at 1-855-314-8390, or write to us at:

Jostens, Inc.

ATTN: Privacy Department

7760 France Avenue South, Suite 400

Minneapolis, MN 55435

United States of America

13. Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “NOTICE TO CALIFORNIA RESIDENTS” section we will refer to this information as “Personal Information.”

If you are a California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available here for more information on our collection and use of your Personal Information in that capacity.

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated date of this Privacy Policy, have collected the following categories of Personal Information:

  • Identifiers (name, postal address, email address)
  • Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
  • Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (signature, telephone number, credit card number, debit card number, as well as the categories listed in “Identifiers” category above)
  • Characteristics of protected classifications under California or federal law (sex/gender, age (40 and older))
  • Commercial information (products or services purchased, obtained or considered; other purchasing or consuming histories)
  • Biometric information (photographs)
  • Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
  • Geolocation data
  • Audio, electronic, visual, or similar information (photographs)
  • Professional or employment-related information (including employment history)
  • Education information

We collect Personal Information directly from California residents and from schools, partners, customers, social networks, advertising networks, marketing partners, and publicly available databases. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “How We Use Your Personal Data” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
  • Debugging to identify and repair errors that impair existing intended functionality
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, or providing similar services
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
  • Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, or services, or enabling or effecting, directly or indirectly, a commercial transaction

Sale, Sharing, and Disclosure of Personal Information

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

Category of Personal Information

Categories of Third Parties

Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)

Data broker; advertising network; data analytics provider

 

We sold or shared Personal Information to third parties for the following business or commercial purposes:

  • Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, or services, or enabling or effecting, directly or indirectly, a commercial transaction

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information. 

Category of Personal Information

Categories of Recipients

Name

Advertising/marketing providers; affiliates; business partners (entities that manufacture products for Jostens, independent sales representatives); customer relationship management platforms; law enforcement/government officials; payment processors; social media platforms

Physical address

Advertising/marketing providers; affiliates; business partners; customer relationship management platforms; law enforcement/government officials; payment processors; social media platforms

Email address

Advertising/marketing providers; business partners; customer relationship management platforms; law enforcement/government officials; social media platforms

Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (telephone number)

Advertising/marketing providers; affiliates; business partners; customer relationship management platforms; law enforcement/government officials

Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (credit card number, debit card number)

Payment processors

Commercial information (products or services purchased, obtained or considered; other purchasing or consuming histories)

Customer relationship management platforms; law enforcement/government officials

Internet or other electronic network activity information (browsing history; search history)

Analytics providers

Audio, electronic, visual, or similar information (photographs)

Business partners

 

We disclosed Personal Information for the following business or commercial purposes:

  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
  • Debugging to identify and repair errors that impair existing intended functionality
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, or providing similar services
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

We do not knowingly sell or share the Personal Information of consumers under 16 years of age. We do not use Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

  • The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
  • The right to delete Personal Information that we collected from you, subject to certain exceptions;
  • The right to correct inaccurate Personal Information that we maintain about you;
  • If we sell or share Personal Information, the right to opt out of the sale or sharing;
  • If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
  • The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct through our interactive webform available here or by calling us toll free at 1-855-314-8390.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.

You may submit a request to opt out of sales or sharing by clicking Your Privacy Choices. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see the “Universal Opt-Out Mechanisms” section above for more information.

Notice of Financial Incentive

From time to time, you may have the opportunity to provide Personal Information in exchange for discounts and price differences. For example, we provide discounts and price differences in exchange for you subscribing to our mailing list. Categories of Personal Information that we may collect when you subscribe to receive discounts and price differences include your email address. 

            How to Opt-In and Right to Withdraw

Signing up for discounts and price differences is optional. By providing your email address during the discount sign-up process, you affirmatively opt in to receiving the financial incentive and to joining our mailing list. You have the right to withdraw from the financial incentive at any time. If you opt out of receiving a financial incentive, we will not reduce the value of any financial incentives you previously received from us. If you wish to withdraw from receiving the financial incentive, you may submit such a request at any time by emailing us at privacy@jostens.com.

How the Financial Incentive is Reasonably Related to the Value of Your Personal Information

The financial incentive or price difference is reasonably related to the value provided by your Personal Information. We take into consideration, without limitation, the anticipated revenue generated from such information, the anticipated expenses which we might incur in the collection, storage, and use of such information, and the anticipated expenses which we might incur related to the offer, provision, and imposition of any financial incentive or price difference. Based on this analysis, the value of your Personal Information that allows us to make these offers and financial incentives is the value of the offer itself.

Shine the Light Law

If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). To make such a request, please send an email to privacy@jostens.com with the subject line “Shine the Light Request.”

Removal of Posted Information by Minors

Our customers who are California residents under 18 years of age (“California Minors”) and are registered users of a Jostens online service, application, or mobile application (“Property”) directed to minors can remove, or request and obtain removal of, content or information posted by the California Minor on such Property. Certain Properties offer functionality to remove posted content. If functionality to remove posted content is not available, California Minors can request removal by emailing remove@jostens.com with “California Minor Content Removal Request” in the subject line and in the body of the message. Please specify in the request the Property to which the request relates and the specific information or content you posted for which you are requesting removal. Please note that the removal of content and information does not ensure complete or comprehensive removal of the posted content or information.

14. Europe and the United Kingdom

If you are in a country in the European Economic Area (EEA) or in the United Kingdom, you are entitled to the following explanation of the legal bases we rely on to process your Personal Data and a description of your privacy rights.

Legal Bases for Processing Your Personal Data

The legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.

Consent

We may process your Personal Data based on your consent such as when you create an account or when you ask us to send certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.

Our Legitimate Interests

We may process your Personal Data if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. For example, when we process your Personal Data to carry out fraud prevention activities and activities to increase network and information security, to market directly to you, to expand our business activities and to improve our services and the content and functionality of our Sites.

To Perform a Contract

We may process your Personal Data to administer and fulfill contractual obligations to you.

To Enable Us to Comply with a Legal Obligation

We may process your Personal Data to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts and to comply with legal process.

Necessary for the Exercise or Defense of Legal Claims

If you bring a claim against us or we bring a claim against you, we may process your Personal Data in relation to that claim.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Data for any specific processing activity, please contact us using the “How to Contact Us” section above.

Your Rights

Access Your Personal Data

You have the right to obtain from us confirmation as to whether or not we are processing Personal Data about you and, if so, the right to be provided with the information contained in this Privacy Policy. You also have the right to receive a copy of the Personal Data undergoing processing.

Rectify Your Personal Data

You have the right to ask us to rectify any inaccurate Personal Data about you and to have incomplete Personal Data completed.

Restrict Our Use of Your Personal Data

You have the right to ask us to place a restriction on our use of your Personal Data if one of the following applies to you:

  • You contest the accuracy of the information that we hold about you, while we verify its accuracy;
  • We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
  • We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
  • You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

Object to Our Use of Your Personal Data

You have the right to object to our use of your Personal Data where our reason for using it is based on our legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).

Delete Your Personal Data

You can ask us to delete your Personal Data if:

  • We no longer need it for the purposes for which we collected it;
  • We have been using it with no valid legal basis;
  • We are obligated to erase it to comply with a legal obligation to which we are subject;
  • We need your consent to use the information and you withdraw consent;
  • You object to us processing your Personal Data where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “How Long Is Your Personal Data Kept” section below.

If you do exercise a valid right to have your Personal Data deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Transfer Your Personal Data to Another Service Provider

You may request that we transfer some of the Personal Data you have provided to you or another service provider in electronic copy. This applies to Personal Data we are processing to service a contract with you and to Personal Data we are processing based on your consent.

To exercise any of these rights, please contact us as described in the “How to Contact Us” section above.

Make a Complaint

If you have any concerns or complaints regarding our processing of your Personal Data, please contact us as described in the “How to Contact Us” section above and we will do our best to answer any question and resolve any complaint to your satisfaction.

If, for whatever reason, you feel we do not meet the standards you expect of us, you are also entitled to make a complaint to your local supervisory authority:

EU Data Protection Authorities (DPAs)

Swiss Federal Data Protection and Information Commissioner (FDPIC)

Information Commissioner’s Office (United Kingdom)

How Long Is Your Personal Data Kept?

We will retain your Personal Data for as long as necessary to fulfill the purposes for which we collect it and as set out in this Privacy Policy and for the purpose of satisfying any legal, accounting, or reporting requirements that apply to us.