Highbar Brand Privacy Notice
Effective Date: May , 2020
This Privacy Notice explains Highbar Brand (“we,” “us,” “our,” or “Highbar Brand”) data practices, defines our users (“you” or “your”) privacy options, and describes how your information is collected and used by Highbar Brand.
Revisions to the Privacy Notice
We may update this policy from time to time and will mark new versions with a corresponding effective date. We recommend you visit the Site to review any changes in our practices. Your continued use of the System constitutes your agreement to our then-current Privacy Notice.
What Information is Collected?
Information Collected Directly from You
We collect personal information about you fill out a “Join Us” form, and participate in surveys. The lawful basis for the collection of this information is fulfilling a contract with you and to respond to your inquiries, Highbar Brand’s legitimate interests, and/or your consent. We collect:
- Email address, phone number, mailing address, and other contact information;
- Information relevant to your qualifications and eligibility for employment, including education and employment history;
- Financial information necessary to process a purchase or other request;
- Business affiliations; and
- Other information related to your requests or inquiries.
Information Collected Automatically
Some of the personal information we collect occurs automatically. We use tracking technologies such as cookies, log files, and pixel tags to automatically collect information when users visit our System. Our lawful basis for the collection of this data is our legitimate interests, necessary for completing your requests and maintaining a functional System, and/or your consent. We collect:
- IP addresses to measure our website traffic and to help provide a more personalized experience;
- Information regarding your browser and other technical specifications required to use our System;
- Your transaction history relating to the use of our products and services;
- Computer data or files, often called “cookies,” which may be sent by your web browser and stored on an individual computer to allow our server to “recognize” you through the navigation of the Site, to better serve ads to our users, and for us to credit your account for various online transactions; and
- Computer data files, often called “web beacons” that are small files embedded in websites and collected from emails or links on third-party sites that allow our server to evaluate the popularity of those links or the information contained in emails or on third-party sites.
Collecting Information from Children Under the Age of 16
Our Site and System are not designed for children, and we do not knowingly collect information from any person under the age of 16.
How Is the Information We Collect Used?
We collect information about you in order to provide you with services and products and to make the System to work properly. We use personal information for a variety of purposes related to our business:
- Providing services and support
Performing the essential functions of the System, including responding to inquiries, fulfilling orders and requests, providing support and troubleshooting, connecting users with distributors, sending users product information, including, but not limited to, quotes and distributor locations, and communicating with users about their use of the System or regarding a user initiated inquiry on the System.
- Assessing qualifications for employment
Reviewing job applications submitted through the System to assess qualifications for employment with Highbar Brand.
- Personalizing user experiences on our System
Tailoring content on the System based on user location, preferences, and other personalization factors.
- Analytics, advertisements, and System improvement
- Compliance with legal obligations
Sharing information to comply with the law or a legal proceeding, such as in response to a subpoena or court order.
Disclosure of Information
We may share information, in the aggregate, regarding your online browsing preferences to evaluate our products or allow the third parties we work with to better serve our users. We will not share personally identifiable information in these instances, other than as described in this Privacy Notice.
We will not share your information with third parties to directly market their products to you. We may provide user information to third-party service providers or vendors for:
- Initiating direct marketing programs on our behalf;
- Data tracking;
- Maintenance or development of our System;
- Development of online products, services, or customer service, or new product development; or
- Other contracted promotional opportunities provided to our users.
Sharing with Affiliates and Distributors
We may also share this information with any subsidiaries, distributors, affiliates, assigns, successors, or other related entities and their respective owners.
We may also share your personal information in connection with law enforcement requests or in response to investigations, subpoenas, court orders, or other legal processes to establish or exercise our legal rights or defend against legal claims, or as otherwise required by law. In these instances, our lawful basis for disclosing your information is our legal obligation.
We may also disclose your information to a third party as part of reorganization or a sale of the assets of Highbar Brand or its subsidiaries or divisions. Any third party to which Highbar Brand transfers or sells the System or related assets will have the right to continue to use the personal and other information that you provide to us.
Third Party Websites and Links
How is User Information Protected?
We maintain administrative, physical, and technical safeguards for all user information collected in our System.
Data Subject Rights
European Union data subjects may have certain rights under the GDPR. If you are a European data subject, you may exercise any lawful rights you may have under the GDPR by emailing us at info@highbarbrand.
Right of Access
You may have the right to access data collected about you. To request access to what information we have collected about you and how it has been used, please contact us.
Right of Rectification
You may have a right to correct any incorrect or incomplete information we have about you. To request a correction, please contact us.
Right to Erasure
In certain circumstances, you may have the right to request that we delete your personal information. To request erasure, please contact us.
Right to Restrict Processing
In certain circumstances, you may have the right to restrict the processing of your personal information. To exercise your right to restrict processing, please contact us.
Right to Data Portability
You may have the right to receive personal data we have collected from you in an accessible format. You may also have the right to have the personal information we have collected from you transferred to another controller. To submit a request, please contact us.
Right to Object
You may have the right to object to the processing of your personal data for direct marketing purposes. To object to the processing of your personal data, please contact us.
Rights Related to Automated Decision Making Including Profiling
You have the right not to be subject to a decision based solely on an automated process (no human involvement) which produces legal effects or significantly affects you in a similar way. We will not make these types of decisions by solely automated processed. If you believe that an automated decision making process was applied to you, please contact us.
Your Other Options
While we work hard to use and disclose our users’ personal information only for the purposes identified above, you can choose not to provide personal information or limit the personal information obtained by us as follows:
- You may have your contact information removed from our marketing lists to inform users of new or relevant products, services, and special offers by clicking on the unsubscribe link in any communication received from us, or by emailing us at info@highbarbrand;
- You may limit the collection of “cookies” and similar technologies through your browser settings. However, this may disable our ability to provide you with the most relevant products or information regarding the System; and
- You may limit the ability of Google Analytics to track your online activity through Google’s Ad Settings.
International Data Processing
Highbar Brand is located in the United States and all data related to the System is collected and processed by Highbar Brand in the U.S. If you are not located in the U.S., your personal data will therefore be transferred to, processed, and stored in a country outside of the country where you live. By submitting your personal information to us, you are consenting to the processing of your personal information in the U.S.
For European Union data subjects, all personal data will be processed for lawful purposes in accordance with the General Data Protection Regulation (GDPR) and as described in this Privacy Notice. If your information is only collected based upon your consent and not for other lawful purposes, you may be entitled to withdraw consent by contacting us at info@highbarbrand. Such withdrawal does not affect the lawfulness of processing prior to the withdrawal of consent. Further, withdrawal of consent does not affect processing of information based on other lawful bases of processing other than consent.
We encourage you to contact us regarding any issue, concern, or complaint at info@highbarbrand. European Union data subjects may file a complaint with a data protection authority regarding our processing of your personal data. For more information, please contact your local data protection authority.
Your California Privacy Rights
If you are a California resident, you have certain rights under California Consumer Privacy Act and other data protection laws, including:
- The right to know the sources of your personal information we have collected in the last twelve months, what we use that information for, whether it is being disclosed or sold, and to whom it is being disclosed or sold.
- The right to “opt-out” of Highbar Brand’s sale of your personal information to any third parties.
- The right, with some exceptions, to have your personal information deleted from Highbar Brand’s possession or control.
- The right to receive equal service and pricing from Highbar Brand even if you exercise any of your privacy rights.
You may submit requests for access or erasure of your personal information by calling toll-free (within the U.S. only) 1-800-248-3855 or emailing info@highbarbrand.
If you submit a request for access or erasure of personal information, you will be required to verify your identity by answering certain questions. We will not disclose or delete any information until your identity is verified.
If you are making a request for erasure, we will ask you to confirm again that you want us to delete your personal information before processing your deletion request.
If you are making a request for access, we may not be able to provide specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your personal information, your account with us, our network or the System.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.
Agents making requests on behalf of California residents must verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.
Our response to a request is at no cost to you. We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Under the California “Shine the Light” law, California residents may request information about our disclosures of certain categories of personal data to third parties (i.e., our affiliates) for such third parties’ direct marketing purpose, by emailing info@highbarbrand or writing to: Highbar Brand (California Privacy Rights), Attn: Director of Marketing, 500 Highbar Brand Way, Blooming Prairie, MN 55917.
If you are under 18 years old, a California resident, and a registered user of any Site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to info@highbarbrand. Your request does not ensure complete or comprehensive removal of what you have posted and the law may not require or allow removal even if requested.
Do Not Track Signals
The System does respond to Do Not Track signals at this time. If a user has the Do Not Track option enabled, the System will not track and analyze your behaviour on the System. However, third-parties affiliated with the System through advertising and other relationships may not respond to Do Not Track signals. We are not responsible for third-party affiliates’ response to Do Not Track signals. Users should check third party privacy policies to determine how they respond to Do Not Track Signals.
For additional information pertaining to our Privacy Notice or any of our data practices, or to submit a request, please contact:
500 Minimizer Way SE
Blooming Prairie, MN 55917