Privacy policy

In the following Privacy Policy, we inform you about the processing of your personal data and the data protection claims and rights to which you are entitled.


1. Why Data Protection?

The purpose is to protect you and us and to comply with legal requirements.

  • Specific products and services
    For certain products and services (e.g. training, events), we will inform you about the processing of personal data there before collecting such personal data, referencing and linking to this Privacy Policy if required.

  • Processing on behalf of you as a controller
    Where we provide services to you as a processor (on behalf of you as a controller), the provisions of the service-specific agreement on processing shall apply to the processing of personal data. 

  • Companies of the Vector Group 
    As a company with an international presence, we are subject to different data protection regulations applying in the countries in which we operate. Such country-specific regulations can be found at the end of this Privacy Policy under no. 10.


2. Who are the controller and contacts?

Vector Informatik GmbH is the responsible controller.

Contact details:
Vector Informatik GmbH
Ingersheimer Str. 24
70499 Stuttgart
Germany
Phone: +49 711-80670-0
E-mail: VGDataprotection(at)vector.com

Our Data Protection Officer’s contact details are as follows: 
Data Protection Officer of Vector Informatik GmbH
Ingersheimer Str. 24
70499 Stuttgart
Germany
E-mail: DataProtection.Officer(at)vector.com


3. Security first!

Which measures Vector takes for data security

The security level required for the protection of your data is ensured by the implementation of suitable technical and organisational measures. These measures are documented by certifications and internal IT security policies and regular monitoring. Within the Vector Group, intercompany agreements on information security and data protection ensure the required security level.

Details can be found here


  1. What data do we process and for what purpose?

Processing for contractual or pre-contractual measures

  • Purchase or commissioning of Vector services

    Data: Name, address, telephone number, e-mail address, company, company position (if applicable), country, contract data

    Purpose: Implementation of contractual measures


  • Request for information or (test) software

    Data: Name, address, telephone number, e-mail address, company, company position (if applicable), country, contract data

    Purpose: Implementation of contractual measures


Processing based on your consent or overriding interests of Vector

  • Visit to a Vector website, homepage or landing page

    Data: IP address, browser type and version, operating system used, referrer URL, host name of the accessing computer, time of the server query.

    Purpose: Data security in order to enable the investigation of unauthorised access or the prevention of misuse of the website


  • Registration, login, contact or feedback forms, survey

    Data: Name, address, telephone number, e-mail address, company, position, country, participation status

    Purpose: Support of visitors, implementation of pre-contractual measures, provision of information to (potential) customers, receipt of feedback, exchange


  • Registration, login, contact or feedback forms, survey

    Data: Name, address, telephone number, e-mail address, company, position, country, participation status

    Purpose: Support of visitors, implementation of pre-contractual measures, provision of information to (potential) customers, receipt of feedback, exchange


Processing based on legitimate (general) interests

  • Building surveillance to provide security for persons and property and for crime prevention

    Data: Recordings of persons that are automatically overwritten

    Purpose: Implementation of security measures for buildings and construction sites


  • Vehicle test drives (e.g. for testing sensor technology and for autonomous driving)

    Data: Recordings of persons that are automatically overwritten

    Purpose: Implementation of safety measures for occupants and road users


  1. Who receives the data (data transfer)?

Your personal data will only be transferred to a third party insofar as this is necessary for the establishment, implementation or termination of a contract with you or for the delivery of goods or services or the commissioning of a service. For certain data processing processes, Vector utilises external service providers who may be given access to personal data of data subjects in order to provide these services. These service providers are carefully selected and are obligated to observe data protection and information security standards and to maintain confidentiality. Such third parties may include other companies within the Vector Group.  

Data processing within the European Union is based on Art. 6 para. 1 lit. b GDPR, which permits the processing of data for the fulfilment of an agreement or pre-contractual measures, or on a legitimate interest on our part in the transfer of personal data within the meaning of Art. 6 para. 1 lit. f GDPR, or on your express consent.  

The transfer of personal data to recipients based outside of the EEA in so-called third countries is possible but will only occur if the recipient maintains an appropriate level of data protection or if you have given your consent to the transfer. If you wish to receive an overview of the recipients in other countries or information about the agreed rules to ensure an appropriate level of data protection, please use the information provided in the "Contact" section.


  1. How long do we store data?

The data are erased as soon as they are no longer required for the purpose for which they were collected.

Data that are stored in log files will be erased after a maximum period of 30 days. It is possible that data will be stored and combined with other data for analysis and optimization purposes, and to improve the information offered on our website. However, in this case, the users’ IP addresses will be erased or altered so that they can no longer be used to identify the accessing client.

Legal and regulatory retention requirements may also require the storing of data for the following purposes:

  • Auditing and billing purposes,

  • Compliance with statutory retention periods,

  • Settlement of conflicts or establishment, exercise or defence of legal claims.


  1. What are your rights?

You have the right to:

  • Information
    As a data subject, you can request information concerning which data about you is being stored or processed.

  • Rectification
    If you discover that the data concerning you is incorrect, you can request that it be corrected promptly.

  • Erasure
    The right to erasure includes the complete removal of your personal data. It is a very strong right that can only be exercised under certain conditions, for example because the processing is no longer necessary.

  • Restriction of processing
    While restriction of processing applies, your data may only be stored but not processed in any other way.

  • Data portability
    You have the right to request the release or transfer of your data.

  • Objection to the processing of data in individual cases
    You may also object to data processing that would generally be considered lawful for reasons that arise from your particular situation.

  • Withdrawal of consent
    You can withdraw your consent at any time. However, all processing of your data that has been carried out up to the withdrawal of consent remains lawful.

  • Right to file a complaint with a data protection supervisory authority
    You are entitled to file a complaint with a competent data protection supervisory authority.


8. Services and cookies - what do we use?

Subject to your consent, we use cookies and third-party services to display and personalise content, analyse traffic to our website or provide convenience features. You can manage the use of cookies with the "Cookie Settings" link shown in the footer of every page on our website, with the exception of the technology required for basic functionalities.

We also collect data in order to obtain statistical information to optimise our products, services and marketing for our business partners and visitors. This is done using various services, which are described below:

  • etracker

    The provider of this website uses the services of etracker GmbH, Hamburg, Germany (www.etracker.com) to analyse usage data. We do not use cookies for web analysis by default. If we use analysis and optimisation cookies, we will obtain your explicit consent separately in advance. If this is the case and you agree, cookies are used to enable a statistical range analysis of this website, a measurement of the success of our online marketing measures and test procedures, e.g. to test and optimise different versions of our online offer or its components. Cookies are small text files that are stored by the Internet browser on the user's device. etracker cookies do not contain any information that could identify a user.

    The data generated by etracker on behalf of the provider of this website is processed and stored by etracker solely in Germany by commission of the provider of this website and is thus subject to the strict German and European data protection laws and standards. In this regard, etracker was independently checked, certified and awarded with the ePrivacyseal data protection seal of approval.

    The data processing is based on Art. 6 Section 1 lit f (legitimate interest) of the General Data Protection Regulation (GDPR). Our legitimate interest is the optimisation of our online offer and our website. As the privacy of our visitors is very important to us, the data that may possibly allow a reference to an individual person, such as IP address, registration or device IDs, will be anonymised or pseudonymised as soon as possible. etracker does not use the data for any other purpose, combine it with other data or pass it on to third parties. You can object to the outlined data processing at any time by clicking on the following checkbox:

    [x] www.vector.com

    The objection has no disadvantageous consequences. If no checkbox is displayed, the data collection is already prevented by other blocking means.

    Further information on data protection with etracker can be found here.


  • FriendlyCaptcha

    Friendly Captcha protects websites and online services from spam and abuse. We integrate program code from Friendly Captcha into certain areas of our website pages (e.g. in a contact form). This means that the visitor’s device connects to Friendly Captcha’s servers in the context of the protected area (e.g. when sending a contact form). Please refer to https://friendlycaptcha.com/legal/privacy-end-users/ for details.


  • Google Analytics

    This website uses Google Analytics, a web analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). Google Analytics uses cookies to enable analysis of how you use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. If you activate the IP anonymization feature on the website, Google will however shorten your IP address in the Member States of the European Union and other States that are contracting parties to the Agreement on the European Economic Area before transmitting it to the United States. Your full IP address will only be transmitted to a server belonging to Google in the United States in exceptional cases and then shortened there.

    On our behalf, Google will use this information for evaluating your use of the website, compiling reports on website activity and providing other services relating to website and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

    Google will not, under any circumstances, associate your IP address with any other data held by Google.

    You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of this website. Furthermore, you can prevent information generated by cookies about your use of the website (including your IP address) being sent to and processed by Google by downloading and installing the following browser plugin. The current link is https://tools.google.com/dlpage/gaoptout?hl=en.

    Please note that this website uses Google Analytics with the extension “_anonymizeIp()” and therefore IP addresses are processed only in a shortened form to prevent them being directly linked to a particular individual.

    Further information concerning Google’s Terms of Service and Privacy Policy can be found at http://www.google.com/analytics/terms/ or at https://policies.google.com/?hl=en.

    By using this website, you consent to the collection, processing and use of data about you by Google in the manner and for the purposes set out above.


  • Google Maps

    This website uses Google Maps on some of its pages to show interactive maps and provide directions (Google Maps is a map service of Google).

    Each time you visit a page on this website that uses Google Maps, a direct connection is established between your browser and a Google server in the United States. The information that you have visited this page using your IP address will be sent directly to Google's server by your browser and stored there.

    When you use Google Maps, information about your use of this website, including your IP address and the (start) address that you entered in the route planner, will be transmitted to Google in the United States.

    If you do not want Google to collect, process or use data about you when you use Google Maps through this website, you can deactivate JavaScript in your browser settings.  However, you will not be able to use the map display function if you do so.

    You will find Google's privacy policy, which provides further details about how it collects and uses your data, about your rights in this respect and about how to manage your privacy settings options at https://policies.google.com/privacy?hl=en.

    By using this website, you consent to the collection, processing and use of data about you by Google in the manner and for the purposes set out above.


  • Google Remarketing

    This website uses Google's remarketing function. Remarketing is a feature that enables us to show you as a visitor to our website targeted ads when you later visit other sites in Google's advertising network. Your browser stores cookies when you visit websites belonging to Google's advertising network. Ads can then be displayed to you on these websites with content from sites which you have already visited if these sites use the Google remarketing function. According to Google itself, it does not collect any personal data during this process. If you do not wish to be tracked using Google's remarketing function, you can opt out of it by adjusting your settings accordingly: http://www.google.com/settings/ads. Alternatively, you can deactivate the use of cookies for targeted advertising by following the instructions provided by the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp.


  • LinkedIn Insights

    We use the LinkedIn Insight Conversion Tool to display interest-based advertising on LinkedIn to vector.com users. The aggregated usage data from the Insight Tag helps us improve our service quality by better understanding how LinkedIn users use our website. Furthermore, with the help of LinkedIn Insight Tags, we can measure if our website visitors take relevant actions. This measurement of conversions can also be carried out across devices. LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser properties and time of access). The IP addresses are shortened resp. pseudonymized when used to reach LinkedIn members across devices. The direct identifiers of members are deleted by LinkedIn after seven days. Remaining pseudonymized data is deleted after 180 days.

    The data collected by LinkedIn cannot be assigned to specific individuals by us as the website operator. LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it as part of its own advertising measures. Details can be found in LinkedIn's privacy policy at https://www.linkedin.com/legal/privacy-policy#choices-oblig.

    Processing takes place on the basis of your express consent which can be revoked at any time. Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

    You can object to the analysis of usage behavior and targeted advertising by LinkedIn at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

    Furthermore, LinkedIn members can control the use of their personal data for advertising purposes in their account settings. To prevent LinkedIn from linking data collected on our website to your LinkedIn account, you must log out of your LinkedIn account before visiting our website.


  • Marketing Automation (Newsletters, Gated Content, Contact Forms)

    As a visitor to our website, you will be offered the option of subscribing to our company newsletter. At Vector, we use our newsletter to inform our customers, business partners and potential customers at regular intervals about our company's offerings. If you would like to receive the newsletter offered on our website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. After registering, you will receive an e-mail asking you to confirm your newsletter registration. We will only send you our newsletter once you have confirmed your registration. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your stored data are also logged. 

    On our website, you also have the option to contact us or request gated content. We process the information you provide in these forms for the purpose of contacting you or providing you with content. The submission of contact forms and the receipt of gated content is also tied to your consent to the creation of a personal user profile based on your data, in which your inquiries and your usage behavior in dealing with Vector's e-mails are recorded through the use of cookies and tracking technology in order to improve the customization of websites and newsletters on products, services and market trends to your specific interests. 

    For newsletters, gated content and contact forms, we use Evalanche, an analysis service provided by SC-Networks GmbH, Würmstrasse 4, 82319 Starnberg, Germany. The emails contain so-called tracking pixels, which allow us to recognize whether an e-mail has been read by you or not. As part of this retrieval, technical information, such as information about the browser and your system, the end device used and the mail client, as well as your IP address and the time of retrieval are initially collected. The information generated by cookies about your use of our offers is analyzed and sent to a server in Germany. Evalanche will not forward this data to third parties. Your data will then be transmitted to our Customer Relationship Management (CRM) system and stored there.

    The legal basis for the processing of your personal data for newsletter marketing, as well as for the use of cookies and tracking technology, is that you have provided your consent (Art. 6(1)(a) GDPR). The logging of the registration process is based on our legitimate interest in fulfilling the obligation of accountability according to data protection legislation (Art. 6(1)(f) GDPR). The processing of the information you provide in contact forms or forms for requesting gated content is carried out on the basis of our legitimate interest for the purpose of contacting you or providing content requested by you (Art. 6(1)(f) GDPR). 

    If you have agreed to receive newsletters, we also carry out scoring activities in order to better understand your needs and send you relevant information. These processing activities are based on our legitimate interest in accordance with Art. 6(1)(f) GDPR. Our legitimate interest lies in continuously improving our services, adapting our offer to your individual needs and providing you with relevant information. 

    Each newsletter contains a link for revoking your consent. By clicking on the "Unsubscribe" link, you can unsubscribe from the newsletter. Alternatively, you can, at any time, unsubscribe from the newsletter by writing to us. Please use the information provided in the section headed "Contact".

    Price Quotations and Product Trials 

    On our website you also have the option of requesting price quotations and software trials in order to test the product free of charge for a limited period of time. By submitting your contact details, you give your consent that we may process your personal data for the purpose of providing the requested content. In this context, your data will be recorded in our Customer Relationship Management (CRM) system and furthermore in Evalanche our analysis service provided by SC-Networks GmbH.

    The legal basis for the processing of your personal data to request price quotations or free trial versions is our legitimate interest pursuant to Art. 6(1)(f) GDPR. 


  • Vimeo and YouTube

    We integrate videos into this website by using YouTube plugins from the internet video portal YouTube of youtube.com, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (hereinafter referred to as "YouTube"), which is represented by Google.

    Each time you visit a page on this website offering one or more YouTube video clips, a direct connection is established between your browser and a YouTube server in the United States. The information that you have visited this page using your IP address will be sent directly to the Google server by your browser and stored there. As a result of your interaction with YouTube plugins (such as starting the video), information generated by the interaction is transmitted to YouTube and stored there.

    If you have a YouTube account and do not want YouTube to collect data about you via our website and to link it to the member data which it stores about you, you will need to log off from YouTube before visiting our website.

    You will find YouTube's Privacy Policy, which provides further details about how it collects and uses your data, about your rights in this respect and about how to manage your privacy settings options at https://policies.google.com/privacy?hl=en.


9. How are changes to this Privacy Policy implemented?

The nature and scope of the processing of your personal data are subject to change, e.g. for technical reasons, which we take into account by adapting our Privacy Policy. You can find the current version on this page.


10. Country specific – What applies in special cases?



  • India
    Any grievances / complaints / queries that you may have can be addressed to our grievance officer, whose details are below and is also published on our website:
    Data Protection Officer of Vector Informatik GmbH
    DataProtection.Officer@vector.com

    Name and address of the entity that will be collecting the personal information:
    Vector Informatik India Pvt. Ltd. Pune

    Name and address of the entity that will retain the information: Vector Informatik India Pvt. Ltd. Pune

    You may choose not to provide the data and information sought to be collected pursuant to this policy, in which case we may not be able to provide you with any services.


  • Japan
    The following special provisions (“Special Provisions”) apply to the processing of personal information by Vector Japan Co. Ltd. ("Vector Japan") and the processing of personal information of a person in Japan, related to the provision of goods or services to a person in Japan, as well as the Section 1 to 9 of our Privacy Policy. In the event of any conflict between the Section 1 to 9 of our Privacy Policy and the Special Provisions, the Special Provisions shall prevail.

    Vector Japan recognizes the importance of personal information, ensures its thorough protection, complies with laws and regulations concerning personal information, and processes your personal information as follows for earning your trust.

     

    Purpose of Processing Personal Information

    In addition to the purpose stated in the Section 1 to 9 of our Privacy Policy, we will process the personal information we collect from you to the extent necessary to achieve the following purposes in our business:

    If you are a customer, we will process the personal information to: 

    A)    To provide important information such as contract renewals, version upgrades, and other changes in terms and conditions related to the licenses of our products used by you.

    B)    To confirm the identity, to confirm the contract, and to respond to, or contact you, in order to provide training, technical support, or other services.

    C)    To provide information about our products and services, and to ask you to participate in surveys such as questionnaires regarding our products and services, in order to provide you with useful information about these products and services.

    In addition, we may contact you regarding product defects that are deemed urgent, unless you explicitly refuse to be contacted.

    If you are a job applicant, we will process the personal information to: 

    A)    provide you with information on recruiting and contact you.

    B)    carry out operational control for recruiting.

    C)    respond to your inquiry
     

    Joint Processing of Personal Information

    If you are a customer, Vector Japan processes your personal information jointly between the Vector Group. The specification is as follows:

    A)    The Items of Personal Data Processed Jointly include
    Name, address, email address, phone number, fax number, and sex, other data stated in Section 4, etc..

    B)    The Scope of the Joint Users
    Vector Group (Vector Informatik GmbH, parent company of Vector Japan, and its affiliates)
    Please see here regarding the Vector Group list.

    C)    The Purpose for which the Personal Data is Used by them
    It is the same as the purpose stated in the Section 1 to 9 of our Privacy Policy and the purpose for the case of customer stated in “Purpose of Processing Personal Information” of stated in the Special Provision.

    D)    The Name of the Controller Responsible for the Management of the Personal Data etc.
    Vector Informatik GmbH
    Ingersheimer Str. 24
    70499 Stuttgart
    Germany
    Managing Director
    Phone: +49 711-80670-0
    E-mail: info(at)vector.com
     

    Request of Information, Rectification, Restriction of Processing, and Others regarding Personal Data

    You have the rights stated in the Section 7 of our Privacy Policy (that is to request notification of the purpose of use of retained personal data, disclosure of retained personal data or records of provision to third parties, rectification, addition, or deletion, restriction of processing, or cessation of provision to third parties (“Disclosure, etc.”), under the Act on the Protection of Personal Information, ).

    Regarding Disclosure, etc. of your personal information, please refer to "Request Form for Disclosure, etc. of Personal Information" for the relevant procedure.

    Security measures of Personal Data
    With respect to personal information (including personal information that will be acquired and treated as personal data by Vector Japan), Vector Japan implements the necessary technical and organizational measures to prevent leakage, loss, or damage, and to otherwise manage personal data appropriately.
    Regarding the data security of Vector Group, please refer to the Section 3.
     

    Vector Japan Co. Ltd.
    31F Shinagawa Season Terrace, 1-2-70, Konan, Minato-ku, Tokyo 108-0075
    President and Representative Director Kiyotsugu Tanno



  • USA
    Country specific regulations for the United States of America

    This page supplements Vectors Privacy Policy which directed you to this page and sets forth information and describes rights that may be applicable to residents of the State of California. The information in both, the aforementioned Privacy Policy and as set forth below also encompasses information for the States where there are requirements regarding privacy policies, including, but not limited to Colorado, Delaware, Florida, New Jersey, Rhode Island, Texas.

    Please also read our information on Services and Cookies under Section 8 of the Privacy Policy which directed you to this page.

    The California Consumer Privacy Act ("CCPA") requires us to provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, sale, sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information.

    This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.

    1. Personal Information Collected

    We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). Personal information does not include:

    • Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.

    • Lawfully obtained, truthful information that is a matter of public concern.

    • 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 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; or

    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act.

     

    2. Personal Information Categories Chart

    Please note that the inclusion of a category below does not necessarily indicate that we collect or hold information in that category about you. The specific personal information we gather depends on how you interact with us, which products and which services you use.

    • Identifiers.
      Example: 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.

      Third Parties to which personal data is disclosed for a business purpose*:
      Affiliates;
      service providers;
      business partners;
      professional advisors such as legal advisors.
      Please also see Section 5 of the Privacy Policy which directed you to this page.

      Business Purpose for Disclosure:
      To process transactions, comply with laws, manage our business, distribute our products or provide services to you


    • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records").
      Example: A name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, membership in professional organizations, professional licenses and certifications, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
      Some personal information included in this category may overlap with other categories.

      Third Parties to which personal data is disclosed for a business purpose*:
      Affiliates;
      service providers;
      business partners;
      professional advisors such as legal advisors.
      Please also see Section 5 of the Privacy Policy which directed you to this page.

      Business Purpose for Disclosure:
      To process transactions, comply with laws, manage our business, distribute our products or provide services to you.


    • Commercial information.
      Example: Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

      Third Parties to which personal data is disclosed for a business purpose*:
      Affiliates;
      service providers;
      business partners;
      professional advisors such as legal advisors.
      Please also see Section 5 of the Privacy Policy which directed you to this page.

      Business Purpose for Disclosure:
      To process transactions, comply with laws, manage our business, distribute our products or provide services to you.


    • Biometric information.
      Example: 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.

      Third Parties to which personal data is disclosed for a business purpose*:
      Affiliates;
      service providers;
      business partners;
      professional advisors such as legal advisors.
      Please also see Section 5 of the Privacy Policy which directed you to this page.

      Business Purpose for Disclosure:
      To process transactions, comply with laws, manage our business, distribute our products or provide services to you.


    • Internet or other similar network activity.
      Example: Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites.

      Third Parties to which personal data is disclosed for a business purpose*:
      Affiliates;
      service providers;
      data analytics providers;
      business partners;
      professional advisors such as legal advisors.
      Please also see Section 5 of the Privacy Policy which directed you to this page.

      Business Purpose for Disclosure:
      To process transactions, comply with laws, manage our business, distribute our products or provide services to you.


    • Geolocation data.
      Example: Physical location or movements, such as the time and physical location related to use of our internet website, application, or device, and GPS location data from mobile devices of consumers who visit our websites or use our mobile apps.

      Third Parties to which personal data is disclosed for a business purpose*:
      Affiliates;
      service providers;
      business partners;
      professional advisors such as legal advisors.
      Please also see Section 5 of the Privacy Policy which directed you to this page.

      Business Purpose for Disclosure:
      To process transactions, comply with laws, manage our business, distribute our products or provide services to you. 


    • Sensory data.
      Example: Audio, electronic, visual, thermal, olfactory, or similar information, including customer service call monitoring and store video surveillance.

      Third Parties to which personal data is disclosed for a business purpose*:
      Affiliates;
      service providers;
      business partners;
      professional advisors such as legal advisors.
      Please also see Section 5 of the Privacy Policy which directed you to this page.

      Business Purpose for Disclosure:
      To process transactions, comply with laws, manage our business, distribute our products or provide services to you.


    • Professional or employment-related information.
      Example: Current or past job

      Third Parties to which personal data is disclosed for a business purpose*:
      Affiliates;
      service providers;
      business partners;
      professional advisors such as legal advisors.
      Please also see Section 5 of the Privacy Policy which directed you to this page.

      Business Purpose for Disclosure:
      To process transactions, comply with laws, manage our business, distribute our products or provide services to you.


    • Sensitive personal information
      Example: Further identified in the chart below under Section 4.1.

      Third Parties to which personal data is disclosed for a business purpose*:
      Affiliates;
      service providers;
      business partners;
      professional advisors such as legal advisors.
      Please also see Section 5 of the Privacy Policy which directed you to this page.

      Business Purpose for Disclosure:
      To process transactions, comply with laws, manage our business, distribute our products or provide services to you.


      * We only make these business purpose disclosures under contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA's other contract requirements for engaging service providers or contractors.



    3. How long do we store data?

    For details on retention periods please see Section 6 of the Privacy Policy which directed you to this page.'


    4. Sensitive personal information

    We may collect the following categories of sensitive personal information in order to process transactions, comply with laws, manage our business, or provide you with services. Please note that the inclusion of a category below does not necessarily indicate that we collect or hold information in that category about you. The specific personal information we gather depends on how you interact with us, which products and which services you use.


    4.1 Sensitive personal information chart

    Sensitive Personal Information Category

    • A. Government identifiers, such as your Social Security number (SSN), driver's license, state identification card, or passport number.
      Collected to Infer Characteristics?: No


    • B. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password.
      Collected to Infer Characteristics?: No


    • C. Precise geolocation, such as physical store visits or physical locations when visiting websites or using mobile apps.
      Collected to Infer Characteristics?: No


    • D. Racial or ethnic origin.
      Collected to Infer Characteristics?: No


    • E. Citizenship or immigration status.
      Collected to Infer Characteristics?: No


    • F. Religious or philosophical beliefs.
      Collected to Infer Characteristics?: No


    • G. Union membership.
      Collected to Infer Characteristics?: No


    • H. Mail, email, or text messages not directed to the Company.
      Collected to Infer Characteristics?: No


    • I. Genetic data.
      Collected to Infer Characteristics?: No


    • J. Neural Data, such as information generated by measuring a consumer's central or peripheral nervous system's activity that is not inferred from nonneural information.
      Collected to Infer Characteristics?: No


    • K. Unique identifying biometric information.
      Collected to Infer Characteristics?: No


    • L Health information.
      Collected to Infer Characteristics?: No


    • M. Sex life or sexual orientation information.
      Collected to Infer Characteristics?: No


      4.2 Sensitive Personal Information Use and Disclosure Purposes

      We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

      • Performing actions that are necessary for our business relationship and that an average consumer in a relationship with us would reasonably expect.

      • Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.

      • Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at us.

      • Ensuring physical safety.

      • Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:

        • disclose the sensitive personal information to another third party; or

        • use it to build a profile about you or otherwise alter your experience outside your current interaction with us.

      • Services performed for us, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for us.

      • Activities required to:

        • verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or

        • improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.

      Please note that we do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes.

     

    5. Additional Categories or Other Purposes

    We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

     

    6. Selling or Sharing Personal Information

    We do not sell your personal information, including sensitive personal information, to third parties and have not sold it in the preceding 12 months. We may share your personal information with third parties for cross-context behavioral advertising purposes and have shared your personal information in the preceding 12 months.

     

    7. Your Rights and Choices

    Among other rights, you have the right to request access, deletion and portability of your personal information as further described in Section 7 of the Privacy Policy which directed you to this page.

     

    8. How We Protect Your Personal Data

    Please see Section 3 of the Privacy Policy which directed you to this page.

     

    9. Privacy Policy Changes

    Please see Section 9 of the Privacy Policy which directed you to this page.

     

    10. Contact Information

    Please see Section 2 of the Privacy Policy which directed you to this page.