The Vollrath Company, L.L.C. (“Vollrath,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy applies to information we collect:
- on our Websites;
- in email, text, and other electronic messages between you and our Websites;
- on or through our Applications which you may download from mobile application stores, like Apple’s App Store® and Google’s Play® store. These Applications may provide a dedicated non-browser-based interaction between you and our Websites or otherwise provide you with the ability to interact with our products and services; and
- when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by Vollrath or any third-party (including our affiliates and subsidiaries);
- us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Data Controller, Data Protection Officer, and Representative
Vollrath is the data controller of the Personal Data you provide on the Websites. At this time, Vollrath is not required to appoint a Data Protection Officer or a representative in the EU.
Children Under the Age of 18
Our Websites and Applications are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Websites or our Applications. We will remove any information from a child under the age of 18 if we become aware of it.
Our Websites and Applications are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Websites or on or through our Applications. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not register on the Websites or through the Applications, use the Applications, make any purchases through the Websites, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at Contact Information below.
Information We Collect About You and How We Collect It
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
We collect several types of information from and about users of our Websites and Applications (“Personal Data”):
- by which you may be personally identified, such as name, postal address(es), e-mail address, telephone number(s), and credit/debit card numbers (for payment processing only);
- that is about you but individually does not directly identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites or use of our Applications, error information, clickstream data, geolocation information, and other communication data and the resources that you access and use on the Websites or Applications; and/or
- about your internet connection, the equipment you use to access our Websites or Applications and usage details.
We collect this information:
- directly from you when you provide it to us;
- automatically as you navigate through the Websites or use our Applications. Information collected automatically are usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
- from third parties, for example, our business partners.
INFORMATION YOU PROVIDE TO US
The information we collect on or through our Websites and Applications are:
- information that you provide by filling in forms on our Websites or in our Applications. This includes information provided at the time of registering to use our Websites or Applications, subscribing to our newsletter, or requesting further services. We may also ask you for information when you enter a contest, sweepstakes, or promotion sponsored by us, and when you report a problem with our Websites or Applications;
- records and copies of your correspondence (including email addresses), if you contact us;
- your responses to surveys that we might ask you to complete for research purposes; and
- details of transactions or operations you carry out through our Websites or Applications and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites or use our Applications.
The Personal Data we collect from you is required to enter into a contract with Vollrath for our goods and services, and for us to perform under the contract and/or to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.
INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you navigate through and interact with our Websites or use our Applications, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. We collect the details of your visits to our Websites and/or use of our Applications and information about your computer, mobile device, and internet connection as described above.
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Websites and Applications and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Websites and Applications according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Websites or open our Applications.
Lawful Basis for Processing Your Personal Data
If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):
- Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Vollrath and you; detect and correct bugs and to improve our Websites and Applications; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; check your credit and perform risk assessments; and further develop and enhance our products and services.
- To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you.
As Required by Law. We may also process your Personal Data: when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
Special Categories of Information
We generally do not request you provide and do not process any special categories of Personal Data.
Vollrath does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you, including personal data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade unions membership, or personal data concerning your health or data concerning your sex life or sexual orientation or history of criminal convictions.
Automated Decisions Making
We generally do not use your Personal Data with any automated decision making processes.
Vollrath does not use your Personal Data with any automated decision making processes that may produce a legal effect concerning you or similarly significantly affect you, including profiling of our users.
How We Use Your Information
We use your Personal Data for various purposes described below, including to:
- provide our Websites to you;
- provide you with information you request from us;
- enforce our rights arising from contracts;
- notify you about changes; and
- provide you with notices about your account.
We use information that we collect about you or that you provide to us, including any Personal Data:
- to present our Websites and Applications and their respective contents and functionality to you;
- to provide you with information, products, or services that you request from us;
- to fulfill any other purpose for which you provide it;
- to provide you with notices about your account;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes to our Websites, Applications, or any products or services we offer or provide though them;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
With your consent, we may also use your information to send you quizzes, surveys, sweepstakes, promotions, or contests or to contact you about our goods and services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by logging into the Websites or the Applications and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by contacting us through the Contact Information below. For more information, see Choices About How We Use and Disclose Your Information
Disclosure of Your Information
- our subsidiaries and our affiliates;
- our third-party service providers that we use to support our business;
- to a company we merge with, acquire, or that buys us, or in the event of change in structure of our company of any form;
- to comply with our legal obligations;
- to enforce our rights; and
- with your consent.
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure support services, email services, and payment processing services. Our payment processor’s privacy policies may be found at http://www.paytrace.net/privacy-policy/;
- to a actual or potential buyer or other successor in the event of a actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of The Vollrath Company, L.L.C.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by The Vollrath Company, L.L.C. about our Websites’ users is among the assets transferred;
- to fulfill the purpose for which you provide it;
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
We may also disclose your Personal Data:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Vollrath Company, L.L.C., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data. We will only use your contact information to promote our own products and services with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. If you wish to change your choice, you may do so at any time by contacting us through the Contact Information below. If we have sent you a promotional email, you may request to be omitted from future email distributions by clicking the unsubscribe link at the bottom of the email. This opt out does not apply to information provided to Vollrath as a result of a product purchase, warranty registration, product service experience or other transactions.
Your Rights Regarding Your Information and Accessing and Correcting Your
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.
- Access and Update. You can review and change your Personal Data we have about you by notifying us through the Contact Information below of any required changes or errors in to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
- Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
- Portability. To the extent the Personal Data you provide Vollrath is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
- Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time, including by closing your account (if you have one). Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
- Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account (if applicable), and we will only delete your Personal Data when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase your Personal Data if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
- Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
- How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.
Do Not Track Signals
We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.
We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites or Applications, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Websites. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites or in the Applications.
State-Specific Privacy Rights
YOUR CALIFORNIA PRIVACY RIGHTS
After January 1, 2010, you have the additional rights described in the California Privacy Addendum.
Consent to Processing of Personal Data in the United States
We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.
If you are a resident of the European Economic Area (“EEA”), in order to provide our Websites, Applications, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.
Data Retention Periods
We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:
- on our backup and disaster recovery systems;
- for as long as necessary to protect our legal interests; and
- and to comply with other legal requirements.
Vollrath will retain your Personal Data for the entire time that you keep your account open (if you have one). After you close your account (if you had one), we may retain your Personal Data:
- for at least two (2) more years;
- for as long as necessary to comply with any legal requirement;
- on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
- for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
- for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.
You may contact our Data Protection Officer through the contact information below. If you wish to contact us, you must contact both us and our representative through the contact information below or through the “Contact Us” page on our Websites.
To Contact Vollrath (Controller)
The Vollrath Company, L.L.C.
1236 North 18th Street
Sheboygan, WI 53082-0611
With an establishment in the EU at:
Attn: Adriana Bristot, Financial Manager
Carrer Del Castanyet 132
Santa Coloma De Farners, Girona, 17430
972 843 201 Ext. 938
Vollrath Privacy Addendum for California Residents
YOUR CALIFORNIA PRIVACY RIGHTS
Our Websites and Applications collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, Vollrath’s Websites and Applications have collected the following categories of Personal Information from its consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
NOTE: Some Personal Information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other Personal Information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
USE OF PERSONAL INFORMATION
SHARING PERSONAL INFORMATION
Disclosures of Personal Information for a Business or Commercial Purpose
Vollrath may disclose your Personal Information to a third party for business or commercial purposes (not including “sales” of your Personal Information as discussed below). When possible, we enter a contract that describes the purposes and requires these third parties to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
Category A: Identifiers.
Category B: California Customer Records Personal Information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Sales of Personal Information
As noted in our Privacy Notice, we do not sell your Personal Information, such as your name, address, phone number, and buying history, as the term “sell” is commonly understood to require an exchange of money.
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Vollrath disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Vollrath delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at (800) 624-2051.
- Visiting one of our Websites.
- Logging into your account on the Websites or Application and visiting “Contact Us” page to make such a request.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the 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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We currently do not provide any such financial incentives: