OUR ROLE IN DATA PROCESSING
The entity responsible for the collection and use (processing) of your personal information is Kore-Tek, which, for the purpose of the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 (“DPA”), is the data controller. You can contact Kore-Tek by email at firstname.lastname@example.org, by telephone at 800-866-9176, or by sending a letter to 255 South 6th Street, Suite 3900, Minneapolis, MN 55402.
The Services are controlled and operated by us from the United States of America (“U.S.”). In accordance with U.S. laws, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal data.
PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG
We collect personal information, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you, when you engage with the Services. As used in this Privacy Notice, “personal information” includes “Personal Data”, as defined under the GDPR and DPA.
We collect personal information from a variety of sources and in a variety of ways, including when you:
- Contact us. When you contact us through the Website, we collect, from you, your personal identifiers (name, email address, and telephone number) and any information you choose to include in your message. We use this information to respond to your questions or inquiries, troubleshoot where necessary, and address any issues you have with the Services. To the extent the EU or UK data protection laws apply, the legal basis for this processing is that it is necessary for the performance of the service requested by you. We retain this information for as long as necessary for the purpose for which it was collected.
- Sign up for our newsletter. When you sign up for our newsletter, we collect, from you, your personal identifiers (name and email address) and your company name. We use this information to send you updates, news, and special offers. You may unsubscribe at any time by clicking the “unsubscribe” option included with each newsletter we send you. Our emails include a tracking pixel that tracks whether you open the email and whether you click banners in the email and your subsequent clicks and usage of our Website. We use this information to send you additional email communications which may be of interest to you, as based on your interaction with our emails and/or Website. You can avoid downloading the pixel by rejecting the download of images in the email. We retain this information for as long as necessary for the purpose for which it was collected. To the extent the EU or UK data protection laws apply, the legal basis for this processing is your consent to receive our newsletter. You can revoke your consent at any time with effect moving forward by emailing us at email@example.com.
Facebook, Twitter, LinkedIn, and YouTube (the “Social Networks”) process personal information in the USA where the laws may be less protective than in your country of residence. For example, in accordance with U.S. laws, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal data.
- Kore-Tek Pages on Social Networks. When interacting with our Social Network Pages, we collect, from you, your personal identifiers (first and last name) and visual information (photograph (i.e., profile picture)), as well as any information that you provide when interacting with our Social Network Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function.
To the extent the EU or UK data protection laws apply, the legal basis for the processing is our legitimate interest in advertising our products via our Social Network Pages and communicating with users, customers, and interested parties.
Because our Social Network Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit.
The content posted on our Social Network Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to firstname.lastname@example.org. We retain this information for as long as necessary for the purpose for which it was collected.
- Community Management. With the help of a third party, we collect, from you, your contact, including “likes”, shares, messages and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts. We use this information to create advertisements that match our Social Network Page and to disseminate them via Facebook based on demographic data. To the extent the EU and UK data protection laws apply, the legal basis for analyzing your content and creating advertisements is our legitimate interest in organizing, facilitating, and optimizing communication with our users and the general public. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to email@example.com. We retain this information for as long as necessary for the purpose for which it was collected.
- Facebook Page Insights. When you visit our Facebook Page, Facebook records your IP address and other information about your usage behavior on our Facebook Page. Facebook collects, through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Facebook app through your mobile device (e.g. smartphone or tablet). Facebook uses this information to provide us with statistical evaluations of the use of our Facebook Page. We receive this information directly from Facebook, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age; gender; city/country; device; inquiries from fans about other Facebook Social Network Pages; region and language settings of the users; proportion of men and women; the number of people reached; clicks on posts, “Likes” and reactions; comments and shared content; and total video views. We use this information to analyze and improve the advertising campaigns we conduct through our Facebook Page. We do not collect or process any other personal information in connection with Facebook’s “Page Insights” function.
To the extent the EU and UK data protection laws apply, we are joint controllers with Facebook for this processing. For the purpose of the EU and UK data protection laws, the legal basis for this processing is our legitimate interest in statistical evaluation of users on our Facebook Page for the improvement and adjustment of our advertising measures based on the information collected. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to firstname.lastname@example.org. We retain this information for as long as necessary for the purpose for which it was collected.
- Information Processed Solely by Facebook. We do not know how Facebook uses personal information for its own purposes, how long the personal information is stored on Facebook or whether Facebook data is passed on to third parties.
If you are currently logged in to Facebook as a user, Facebook automatically collects, through trackers on your device, your Facebook ID or a link between the Facebook ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Facebook app through your mobile device (e.g. smartphone or tablet). This enables Facebook to understand that you have visited our Facebook Page along with other Facebook pages that you have clicked on, whether you clicked on Facebook buttons integrated into websites that partner with Facebook, and other online interactions that report user data to Facebook. Based on this data, content or advertising tailored to you can be offered.
- Interact with the Services. In addition to the personal information you provide directly to us, we also collect information from you automatically as you use our Services via “cookies” and similar tracking technologies. To the extent the EU and UK data protection laws apply, the legal basis for placing and accessing the “cookies” is your consent. To the extent the EU and UK data protection laws apply, the further processing of information collected through the analytics cookies and other technologies on the Website, the legal basis for this processing is your consent. You can revoke your consent at any time with effect moving forward by managing your Cookie Preferences. To the extent the EU and UK data protection laws apply, the legal basis for the placement and access of strictly necessary cookies is that they are necessary to provide the Website to you. We use essential, performance, marketing, and analytics cookies to collect your usage, device, and location information (determined through your IP address) when you interact with the Services.
We use this information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse; and (vi) market to you more effectively across different web pages and social media platforms based on your browsing habits and history. We retain this information for as long as necessary for the purpose for which it was collected.
Aggregate data. We aggregate the data we collect for benchmarking purposes and for internal analytics.
Kore-Tek will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.
HOW WE SHARE YOUR PERSONAL INFORMATION
A. General Sharing
Kore-Tek shares personal information in the following instances:
- In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings. To the extent the EU or UK data protection laws apply, the legal basis for this is our legitimate interest in carrying out our business operations.
- With Third Parties. We may need to disclose your personal information to third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, and to comply with our legal obligations. To the extent the EU or UK data protection laws apply, the legal basis for this is our legitimate interest in providing the Services/carrying out our business operations more efficiently.
- For legal purposes. We share your personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law. To the extent the EU or UK data protection laws apply, the legal basis for this processing is compliance with the law and our legitimate interest in compliance with other laws that apply to Kore-Tek.
- With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time with effect going forward by emailing us at email@example.com.
B. Sharing in the Last Twelve (12) Months
For a business purpose. In the preceding twelve (12) months, Kore-Tek has disclosed the following categories of personal information for a business purpose to the following categories of third parties.
- We have disclosed your personal information to service providers that assist us in providing the Services. These service providers assist us with the following: IT support; website hosting; data analysis; order fulfillment; payment processing; customer service; email delivery; text messaging; auditing; and similar services.
- We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Website and platform.
- We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to update, improve, and maintain the Website and platform.
- We have disclosed your internet or other electronic network activity information to advertising providers to measure the effectiveness of our online promotional campaigns.
RIGHTS OF INDIVIDUALS IN THE EUROPEAN UNION AND UNITED KINGDOM
Individuals in the EU and UK are entitled certain rights to their personal data under applicable law. To the extent these laws apply to our processing of your personal data, you are entitled to the following rights:
- Right to access: You have the right to ask us for copies of your personal data. This right has some exemptions, which means you may not always receive all the personal data we process. Applicable exemptions may include the management information exemption (data that we process for management forecasting or management planning about a business or other activity), confidential references (references given or received about an individual), or certain instances of ongoing or prior negotiations with the requestor, among others.
- Right to rectification: You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to erasure: You have the right to request erasure of your personal data that we are not obligated to keep in some cases (also known as the right to be forgotten). For example, you can request us to delete your personal data if: (i) we no longer need the data for the purpose it was collected for, (ii) we process the data based on your consent and you revoke your consent, (iii) you object to our processing based on legitimate interest (and we do not have an overriding legitimate interest), or (iv) you object to our processing for direct marketing purposes. We may not be able to immediately erase your personal data if we have a lawful reason or a legal or contractual obligation to retain the personal data or continue the processing.
- Right to restrict processing: If you believe that your personal data is inaccurate, that our processing is unlawful, or that we do not need your personal data for a specific purpose, you have the right to request that we restrict the processing of this personal data. You also have the possibility to request that we stop processing your personal data while we assess your request. If you object to our processing (per your right to object below), you may also request us to restrict processing of your personal data while we make our assessment.
- Right to object to processing: You have the right to object to processing of your personal data which is based on our legitimate interest, by referencing your personal circumstances.
- Right to data portability: You have the right to ask that we transfer the personal data you gave us from one organization to another or give it to you. However, this right only applies when: (i) you have provided your personal data to us; (ii) the legal basis for the processing is your consent or for the performance of a contract; and (iii) the processing is carried out by automated means.
To exercise these rights, please contact us at firstname.lastname@example.org.
Right to lodge a complaint: You have the right to lodge a complaint with your European Union national data protection authority: https://edpb.europa.eu/about-edpb/about-edpb/members_en
DO NOT TRACK
We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We implement and maintain reasonable security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.
The Services are not intended for individuals under the age of eighteen (18) years. If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. If you believe we have personal information on individuals under the age of eighteen (18), please contact us at the contact information provided below.
CHANGES TO THIS PRIVACY NOTICE
We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.
If you have any questions or concerns regarding this Privacy Notice, please contact us by email at email@example.com, by telephone at 800-866-9176, or by sending a letter to 255 South 6th St, Suite 3900, Minneapolis, MN 55402.