Siemon Privacy Policy

The Siemon Company (“Siemon”) is committed to protecting and preserving your privacy.  This policy, together with our Terms of Use and Conditions, and any other underlying agreements or terms, sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us.  By using our website (“Site”), you are accepting the practices described in this Privacy Policy. This Privacy Policy also describes the manner in which we collect, process, use and disclose information that you provide to us when you use our Site, details of the data we collect, use, disclose and transfer, as well as choices you can make and the rights you can exercise in relation to your data.

By using this Site, you consent to the use of the information that you provide to us in accordance with this Privacy Policy.  We do update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we will notify you of such changes by posting a notice on our Site. Your continued use of the Site will be deemed your agreement that your information may be used in accordance with the new policy.  If you do not agree with the changes, then you should stop using the Site, and you should notify us that you do not want your information used in accordance with the changes.

1. Information we collect.

Siemon collects information about our Site users to provide our services or products and to enable us to deliver our services or products in the best possible way. To facilitate that, it is necessary for us to collect, process, disclose and/or use the information as stated in this Policy. This means that our data collection is very much essential in fulfilling the relationship we have with our Site users.

We will only share the information we collect with our specified partners to make it possible for us to carry out the services requested by our users. As part of our business operations, Siemon may disclose your personal data to its partners and/or distributors to facilitate sales and delivery of its products/services. The partners and distributors are required by contract to hold the data obtained from Siemon confidentially and securely and process the information only for the specified purpose, unless otherwise authorized by you if required by law, or as permitted by applicable laws and regulations.

In addition, we may collect your IP address and use cookies, unless you configure your web browser not to accept them. We may use them for authentication purposes, analytics and to remember users’ settings. You can control the use of cookies at the individual browser level; and at times, if cookies are disabled, certain features of the web pages may not work properly and may stop your access to certain information. For more information on our use of cookies, see section below.

Siemon may provide links to third-party applications, products, services or websites for your convenience or information with your consent. Siemon may offer social-media features that will allow you to share information with social networks and to interact with us on various social-media platforms. These third-party websites and their privacy practices are not controlled by Siemon. We do not make any endorsements or representations about third-party websites. This Policy does not cover the personal information you provide to, or that is collected from you, by third parties.

By connecting and interacting with us using social-media platform like Facebook, LinkedIn, Twitter, YouTube or any other social-networking website, Siemon may obtain information that you have authorized the social-networking website to share with us (e.g. public profile information, email address, comments, feedback, etc.). We will use, disclose and process any data that we collect from these social media platforms in accordance with this Policy.

We encourage you to review the privacy policy of any website you interact with before allowing the collection and use of your personal information.

By submitting a telephone number to Siemon you agree that a representative of Siemon can contact you at the number you provide, potentially using automated technology (including texts/SMS messaging) or a pre-recorded message.  Your consent is not an obligation to receive any of our products and/or services.

2. Information you give us.

We collect personal information only if required to provide our products or services, fulfil our legitimate business purposes and/or comply with applicable laws and regulations. Depending on the Site user’s relationship with Siemon, we collect and process personal information as follows:

For Siemon products/services: contact details and login credentials to enter into a contract and fulfil agreements with you, provide support, manage and implement orders, deliver services and products, conduct quality controls, consult, develop and improve our products/services and comply with regulatory and legal requirements.

For sales and marketing: contact details, identification details, information necessary to purchase our products and services online, login credentials, profile, preferences, digital activity information and other information as may be relevant (e.g. information from publicly available sources) to serve the following purposes: sales and marketing; advertising; creating and delivering targeted advertisements and offers; conducting marketing campaigns; managing contacts and preferences; generating leads and opportunities; organizing and managing events; and engaging in social media interactions.

For partner and supplier programs: contact information to manage relations with partners and suppliers; engage and deliver services and products to customers in which case Siemon may obtain personal information directly from you or from our partners.

Through online data collection tools: digital activity information to enable efficient use of our Site, services; collect statistics to optimize the functionality of our Site, products and services; enhance user experience and deliver content customized to user’s interests; and improve marketing and advertising campaigns.

Through online forums and surveys: contact details, login credentials, comments and feedback for the following purposes: engaging with partners and suppliers in online forums; conducting customer satisfaction and engagement surveys. (e.g. SurveyMonkey & JotForm).

3. How we use, share and disclosure information.

Siemon does not sell, rent or lease, or share your personal information for cross-context behavioural advertising, except as stated in this Policy. We may use, share and/or disclose your personal information as follows:

Disclosure within Siemon: Siemon has its headquarters in the United States of America and operates worldwide and may disclose your personal information as necessary within our group of companies to provide our products/services to you.

Disclosure to Third Parties to Provide Products and Services: Siemon maintains suppliers and service providers to facilitate and support its business operations, offer professional services, deliver products, services and customer solutions and help Siemon with marketing and sales communication initiatives. Those third parties may receive and process your personal information pursuant to a written agreement and/or in accordance with applicable law(s), as necessary to support and facilitate our business operations. These third parties are necessitated by contract to store and process the information confidentially and securely on behalf of Siemon and use it only to perform the services as stated.

Disclosure to Third Parties for Site Monitoring: We may also use your information in order to provide third parties with statistical information about users of our Site, analyze our Site traffic and usage patterns or other trends.

Disclosure to Law Enforcement: We may disclose your information pursuant to law enforcement requests and as required by applicable law, subpoena, court order or governmental regulations.

Disclosure for Sale/Merger: We may disclose your information in order to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users is among the assets transferred.

We will not use personal information for purposes other than to provide you with our products and/or services, or as otherwise expressly permitted by applicable law. We will not use your personal information for cross-context behavioural advertising.

We will not use personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice and/or updating this Policy.

4. How Long We Keep Your Personal Information.

In general, Siemon keeps personal information for the length of any contractual relationship and, to the extent permitted by applicable laws, after the end of that relationship for as long as necessary to perform purposes set out in this Policy, to protect Siemon from legal claims and administer our business. When we no longer need to use personal information, we will delete it from our systems and records or take steps to anonymize the data unless we need to keep it longer to comply with a legal or regulatory obligation.

5.   Security

To secure your information, we have put in place commercially suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect on our Site.

Nonetheless, the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically on our Site, and transmission of such data is therefore entirely at your own risk.

6.   How we Use Cookies

A “cookie” is a piece of text which asks permission to be placed on your computer’s or device’s hard drive. Once you agree, this cookie file is stored on the hard drive of your computer or device.  They help us and our affiliates to improve our Site.  They present the content from our Site in the most effective manner for you and your computer or device.

All browsers have the ability to decline cookies.  This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our Site.

We do not track our users across time or across websites.

We do not use flash cookies on our Site.

7. Users Only of Legal Age of Majority

Our Site is designed and intended for those who have reached the age of majority (18 years of age). By using our Site, you affirm that you are at least 18 years of age or older.  We are not liable for any damages that may result from a user’s misrepresentation of age.

No one under age 13 is authorized to submit or post any information, including personally identifying information, on our Site. Under no circumstances may anyone under age 13 use our Site.  Parents or legal guardians of children under 13 cannot agree to these Terms on their behalf.

8.   California Residents

If you are a resident of California, you have the following rights under the California Privacy Rights Act/the California Consumer Privacy Act (“CPRA/CCPA”):

1. To know what categories of personal information about you we have collected and used, including how the personal information was collected;
2. To know what categories of personal information is being sold or disclosed and if it is being sold or disclosed to third parties and a list of categories of information that are sold, or, as applicable: to know that your personal information has not been sold;
3. To opt out of the sale of your personal information, if we sell such data (click here for more information on “Personal Information Sales Opt-Out and Opt-in Rights”;
4. To access your personal information, including the right to download or transfer personal information collected during the previous 12 months (click here for more information on “Access to Specific Information and Data Portability Rights);
5. To request that your personal information be corrected;
6. To request that we limit our use of your sensitive personal information, if such data is collected;
7. To request that your personal information be deleted (click here for more information on “Deletion Request Rights”;
8. To request that we not use your personal information for cross-context behavioral advertising, if we use your data for such purpose; and
9. To equal service and equal price for goods or services even if you exercise your rights under the CPRA/CCPA.

Note that while California residents have the right to opt-out of the sale or sharing (for cross-context behavioral advertising) of their personal information, we do not sell or share (for cross-context behavioral advertising) personal information to any third parties, and therefore, we have not included a “Do Not Sell or Share My Personal Information” link or a “Do Not Sell or Share my Personal Information for Cross-Context Behavioral Advertising” link on our Site. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law.

If you are a California resident and you want to exercise any of your rights as set forth above, please contact us at 1-860-945-4200 or email us at customer_service@siemon.com. For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and provide your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. For more information click here.

We will not discriminate against you for exercising any of your CPRA/CCPA rights. Unless permitted by the CPRA/CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

9. European Economic Area (EEA) Residents

We process EEA data subject’s personal data on the following legal bases:

Legitimate Interest: We may process the personal data as necessary to pursue our legitimate business interests (except where such interests are overridden by the interests, rights or freedoms of the data subject) particularly for managing, developing and improving our products and services; supporting our customers; performing our marketing and sales operations; protecting our employees and assets; and ensuring compliance with laws and regulations.

Legal Obligation: We may process the personal data to comply with applicable laws and regulations, establish or exercise our legal rights (for example, in connection with legal claims, compliance, regulatory and investigative purposes).

Performance of a Contract: We may process the personal data to enter into a contract and/or fulfil agreements with you or your organizations, including managing and delivering our services and products and allowing our customers to use our products/services and supplementary tools.

Consent: We may process the personal data with the consent of the EEA data subject. In particular, where we cannot rely on an alternative legal basis or we are required by law to ask for your consent in the context of some of our sales and marketing activities, online data collection tools or surveys. At any time, you have a right to withdraw your consent by changing your communication choices, unsubscribing from our communications or contacting Siemon Office using one of the methods listed below.

Except as described in this Policy, Siemon will not disclose EEA resident personal data with third parties without the consent of the EEA data subject, unless for: (i) responding to duly-authorized information requests from police and governmental authorities; (ii) complying with law, regulation or court order; (iii) enforcement and protection of the rights and properties of Siemon; or (iv) protection of the rights or personal safety of our employees and third parties on or using Siemon property when allowed and in each case in compliance with applicable laws.

If you are a resident of the EEA, you can contact the following European Data Controller in exercise of your data protection rights:

Contact details of the Data Controller:

Regional Headquarters Europe
36-48 Windsor Street
Chertsey
Surrey
KT16 8AS
United Kingdom
Tel: +44(0)1932 571 771
Fax: +44(0)1932 575 070
Hours: 8:30 – 5:30 GMT & BST
E-mail: GDPR@siemon.com
Website: http://siemondev.wpenginepowered.com/

Data Subject Rights

If you are a resident of the EEA, you have the following data protection rights.

• Request access or copies of personal data Siemon processes about you;
• Rectify your personal data, if inaccurate or incomplete;
• Delete your personal data, unless an exception applies. For instance, we may need to keep your personal data to comply with legal obligation;
• Data portability, in certain circumstances. For instance, you may request us to transmit some of your personal data to another organization if the processing is based on your consent or a contract;

Siemon strives to keep personal data accurately recorded. We have implemented technology, management processes and policies to help maintain data accuracy. Siemon has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect, or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments.

In accordance with applicable laws, Siemon provides individuals with reasonable access to personal data that they provide to us and the reasonable ability to review and correct it.

To protect your privacy and security, we will take reasonable steps to verify data subject’s identity before granting access to personal data. To view and update the personal data provided directly to Siemon, data subject can return to the web page where data was originally submitted and follow the instructions.

Data subject’s rights to restriction of, or objection to, processing of their personal data.

The data subject has following rights in regard to the restriction of, or objection to, processing of their personal data:

• Restrict the processing of your personal data, in certain circumstances. For instance, if you contest accuracy of your personal data you may request that we restrict processing of your personal data for the time enabling us to verify the accuracy of your personal data;
• Object to processing of your personal data, in certain circumstances. For instance, you may object to direct marketing including use of your personal data for profiling for direct marketing or where we process your personal data because we have legitimate interest in doing so.

Data subject’s rights to withdraw consent at any time.

At any time, data subjects have the right to withdraw their consent by changing their communication choices, unsubscribing from our communications or contacting us at GDPR@siemon.com.

Data subject’s right to lodge a complaint with a supervisory authority.

If the data subject considers that the processing of his/her personal data infringes the GDPR, he/she has the right to lodge a complaint with a supervisory authority in the EEA country where the data subject live, or work, or where he/she considers that data protection rules have been breached.

The data subject has additional rights under our BCRs. For instance, as a third party beneficiary, where you believe your personal data has been transferred to our company located outside the EU and processed by that company in breach of the BCR, you may have a right to lodge a complaint with a supervisory authority located in the same country as the Siemon company in EU which transferred your data outside the EU

10. International Transfers of Personal Data.

As Siemon operates worldwide, we may disclose your personal data as necessary within our worldwide office in the Americas, Europe, Central Asia, Africa, Middle East, India, Asia and Australia. We have an intra-company agreement on the transfer and processing of personal data within our companies across the globe. This forms the basis of our rules for Controller and allows Siemon to ensure that EEA personal data which is transferred and processed by our companies outside the EEA, is adequately protected in accordance with applicable data protection laws. Intra-group international data transfers are subject to legally-binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.

We will only share your information to specified partners overseas to enable us to perform services requested by you. With regard to the transfer of personal data to a third party in a country that does not provide an adequate amount of data protection, Siemon will take appropriate measures in accordance with applicable law(s), which may include execution of the EU’s Standard Contractual Clauses with the recipient.

Circumstances may arise where, whether for strategic or other business reasons, Siemon decides to buy, merge, sell or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal data to prospective or actual purchasers, or the receipt of it from sellers. It is Siemon’s practice to seek appropriate contractual protection for EEA personal data in these types of transactions.

11. Accessibility Statement

We are committed to making sure that our Site is accessible to everyone. To access this Privacy Policy in an alternative form, please email customer_service@siemon.com. For more information, please see our Accessibility Statement.

12. Contacting Us

We welcome any queries, comments, complaints or requests you may have regarding this Privacy Policy.  Please do not hesitate to contact us at:

The Siemon Company
Siemon Business Park
101 Siemon Company Drive
Watertown, CT 06795-0400 USA
1-860-945-4200
customer_service@siemon.com