STORAGE OF ACCESS DATA IN SERVER LOG FILES
You can visit the Site without giving any personal information. We only store access data in ‘server log files’, such as the name of the file requested, date and time of retrieval, amount of data transferred and the requesting provider, for example. This data is evaluated solely to ensure trouble-free operation of the site and to improve our service and does not enable any conclusions of a personal nature to be drawn.
Our primary goals in collecting Personal Data are to conduct our business operations and improve our Site.
PERSONAL INFORMATION WE COLLECT
Depending on how you access, use or otherwise interact with us directly or through our Website, we, or third parties acting on our behalf, may collect personal data about including as part of an order or when you contact us (by contact form or email, for example) or open an account. The data collected includes, but is not limited to, demographic information, such as your first and last name, gender, ethnicity, national origin, and other similar information; financial information, such as your credit card number, debit card number and other similar information (to the extent you supply to us voluntarily); location information, such as where you live, where you are located and other similar information; preference information, such as your interests, hobbies, opinions and other similar information; and delivery address In certain instances data you provide is necessary for the performance of pre-contractual measures. Without these data points we may not be able to provide you with services or products. When you visit our Site, we automatically receive your computer’s IP address, in order to determine which browser and operating system you are using. We use the data provided by you for processing your requests.
To make the visit to our Site attractive and to enable the use of certain functions, we use ‘cookies’ on various pages. These are small text files that are stored on your Device. Some cookies we use (called ‘session cookies’) are deleted after the end of the browser session, i.e., after closing your browser. Other cookies remain on your Device and allow us to recognize your browser on your next visit (‘persistent’ cookies). You can set your browser so that you are notified about cookie settings and individually decide on their acceptance or block the acceptance of cookies for specific cases, or in general. Not accepting cookies may limit the functionality of our Site.
To make the visit to our Site attractive and to enable the use of certain functions, we use ‘cookies’ on various pages. These are small text files that are stored on your device. As such, when you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
You can set your browser so that you are notified about cookie settings and individually decide on their acceptance or block the acceptance of cookies for specific cases, or in general. Not accepting cookies may limit the functionality of our Site.
HOW DO WE USE YOUR PERSONAL INFORMATION
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
SHARING YOUR PERSONAL INFORMATION
Third party providers such as Facebook, Instagram, Twitter, LinkedIn and Google collect and process the data necessary to perform their services. Some of these third parties have their own privacy policies with respect to the information we provide them for transaction processing purposes. We encourage you to read these privacy policies in order to understand how these third-party providers process your information. In particular, please note that certain third-party providers do not have a registered office or server in the United States, or in your jurisdiction. As such, if you choose to use a third-party payment method, your data and the processing thereof may be governed by the law of that third-party provider.
We share your Personal Data with third parties to help us use your Personal Data, as described above.
Finally, we may also share your Personal Data to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect and enforce our rights.
As described above, we use your Personal Data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising at any of the links below:
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Lastly, to the extent you receive any direct mail from us you can opt out of this by visiting the Direct Marketing Association at: https://dmachoice.thedma.org/.
DO NOT TRACK
Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Our services are generally not directed to children under 16. We do not knowingly collect Personal Data from anyone under 16 without parental consent. If you become aware that we have collected Personal Data from a child under the age of 16 without parental consent, please let us know so we can take appropriate action.
If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your Personal Data to third parties for direct marketing purposes: (1) the categories of Personal Data we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.
You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:
Walk West, Inc.
Attn: CA Privacy Rights Request
1730 Varsity Drive, Suite 200
Raleigh, NC 27606
HOW WE PROTECT PERSONAL INFORMATION
In proportion to the sensitivity of the information, we maintain reasonable administrative, technical, and/or physical safeguards and appropriate security measures to protect Personal Data from loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide. However, we cannot guarantee the security of your Personal Data, as no electronic data transmission or storage of information is completely secure. If an incident is reported affecting your information, we will investigate and comply with all required reporting obligations.
WEB BEACONS; PIXELS
Other tracking technologies, such as web beacons, clear gifs, and pixel tags. These technologies may be used on or in connection with our Site, including, without limitation, in emails we send. We may use these technologies to deliver cookies, count visits, understand usage, and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.We currently use web beacons and pixels with the following third-party partners: Facebook, Instagram, Twitter and LinkedIn.
USE OF GOOGLE ANALYTICS FOR WEB ANALYTICS; GOOGLE TAG MANAGER
This Site uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (www.google.com). Google Analytics uses methods enabling analysis of your use of the Site, such as “cookies”, text files stored on your computer. Hereby, data regarding geographic location, language settings, internet browser, internet service provider, operating systems, screen resolution, device type, gender, age, personal interest, online behavior on the Site, are collected by Google LLC and used by Walk West, in the form of statistics for the purpose of improving our products, marketing activities, website and its functioning. The information used by Walk West in this context, does not permit any conclusion in respect of the identity of a concerned individual person.
The information generated about your use of this Site is usually transmitted to a Google server in the United States and stored there. By activating the IP anonymization on this Site, the IP address used will be abbreviated prior to transmission within European Union member states or other states contracting to the Agreement on the European Economic Area. The anonymized IP address provided by Google Analytics within the Google Analytics framework will not be amalgamated with other Google data.
You can prevent Google’s collection of data generated by the cookie and related to your use of the Site (including your IP address), as well as Google’s processing of this data, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
USE OF FACEBOOK PIXEL FOR WEB ANALYSIS
With respect to Facebook, Inc., located at 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”), in addition to web beacons and pixels, we also use “Custom Audience Pixel” analysis software as well as Facebook Audience to optimize our advertising campaigns.
The Custom Audience Pixel software enables online behavior to be observed in terms of time, geographic location, purchase behavior and use of this Site. This information is collected via web beacons and/or cookies. The information received from the web beacons and/or cookies is anonymous and will not be linked to personal data. This information will not be shared with third parties for their own use. Further information can be found at: https://en-gb.facebook.com/business/learn/facebook-ads-pixel.
USE OF FACEBOOK PLUGINS
Our Site uses social plugins of the Facebook social network, operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The plugins are identified by a Facebook logo or the addition of “Facebook Social Plugin”.
If you visit a page on our Site that contains this plugin, your browser connects directly to the Facebook servers. The content of the plugin is transmitted by Facebook directly to your browser and integrated into the page. Through this integration, Facebook receives the information that your browser has accessed on the corresponding page of our Site, even if you do not have a Facebook profile or are not currently logged in to Facebook. This information (including your IP address) will be transmitted from your browser directly to a Facebook server in the United States and stored there.
If you are logged in to Facebook, Facebook can immediately attribute your visit to our Site to your Facebook profile. If you interact with the plugins by clicking the “Like” button or by leaving a comment, for example, the corresponding information is also transmitted directly to a Facebook server, and stored there. The information will also be posted on your Facebook profile and displayed to your Facebook friends.
If you do not wish Facebook to directly assign the data collected via our Site to your Facebook profile, you must log out of Facebook before visiting our Site. You can also completely prevent the loading of Facebook plugins with add-ons for your browser, such as a “Facebook Blocker” or script blocker, for example.
USE OF LINKEDIN PLUGINS
On our Site we use the analysis and conversion tracking technology of the LinkedIn platform, LinkedIn Corporation, 1000 W. Maude Ave., Sunnyvale, California 94085, USA. With this LinkedIn technology, you can see more relevant advertising based on your interests. We also receive aggregated (summarized in a certain way) and anonymous reports from LinkedIn about ad activity and information about how you interact with our Site. We also may embed a plugin, in which case LinkedIn receives the information that you have accessed our website from your IP-address. Please note that the information is exchanged when you visit our Site, regardless of whether or not you interact with the plugin.
USE OF TWITTER PLUGINS (E.G. THE “TWEET” BUTTON)
Our Site uses social plugins of the Twitter microblogging service, operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”). The plugins are identified by a Twitter logo, in the form of a blue “Twitter bird”, for example.
If you visit a page on our Site that contains this plugin, your browser connects directly to the Twitter servers. The content of the plugin is transmitted by Twitter directly to your browser and integrated into the page. Through this integration, Twitter receives the information that your browser has accessed the corresponding page of our Site, even if you do not have a Twitter profile or are not currently logged in to Twitter. This information (including your IP address) is sent from your browser directly to a Twitter server in the United States and stored there.
If you are logged in to Twitter, Twitter can immediately attribute your visit to our Site to your Twitter account. If you interact with the plugins by clicking on the “Tweet” button, for example, the corresponding information is also transmitted directly to a Twitter server and stored there. The information will also be posted on your Twitter account and displayed there to your contacts.
If you do not wish Twitter to directly assign the data collected via our Site to your Twitter profile, you must log out of Twitter before visiting our Site. You can also completely prevent the loading of Twitter plugins with add-ons for your browser, such as a script blocker, for example.
USE OF PINTEREST PLUGINS
Our Site uses social plugins of the Pinterest social network, operated by Pinterest Inc., 651 Brannan Street, San Francisco, CA 94103, USA (“Pinterest”). The plugins are identified by a Pinterest logo.
If you visit a page on our Site that contains this plugin, your browser connects directly to the Pinterest servers. The content of the plugin is transmitted by Pinterest directly to your browser and integrated into the page. Through this integration, Pinterest receives the information that your browser has accessed the corresponding page of our Site, even if you do not have a Pinterest profile or are not currently logged in to Pinterest. This information (including your IP address) is sent from your browser directly to a Pinterest server in the USA and stored there.
If you are logged in to Pinterest, Pinterest can immediately attribute your visit to our Site to your Pinterest account. If you interact with the plugins by clicking on the “Pin it” button or by leaving a comment, for example, the corresponding information is also transmitted directly to a Pinterest server, and stored there. The information will also be posted on your Pinterest account and displayed there to your Pinterest followers.
If you do not wish Pinterest to directly assign the data collected via our Site to your Facebook profile, you must log out of Pinterest before visiting our Site. You can also completely prevent the loading of Pinterest plugins with add-ons for your browser, such as a script blocker, for example.
USE OF VIMEO
Our Site uses features provided by the Vimeo video portal. This service is provided by Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA.
If you visit one of our pages featuring a Vimeo plugin, a connection to the Vimeo servers is established. Here the Vimeo server is informed about which of our pages you have visited. In addition, Vimeo will receive your IP address. This also applies if you are not logged in to Vimeo when you visit our plugin or do not have a Vimeo account. The information is transmitted to a Vimeo server in the United States, where it is stored.
If you are logged in to your Vimeo account, Vimeo allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Vimeo account.
EUROPEAN USER RIGHTS
If you are located in the EU, Switzerland, or the United Kingdom, you have certain rights with respect to your Personal Data. Following is a summary of those rights and additional information applicable to our collection and use of your Personal Data.
Legal Basis for Processing
– We rely on several legal bases to process your Personal Data. These legal bases include where:
– The processing is necessary to perform our contractual obligations, such as to provide you with access to our Site;
– You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
– The processing is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims; and
– The processing is necessary for the purposes of our legitimate interests, such as improving, personalizing, and developing our Site, marketing new features or products that may be of interest, and promoting safety and security as described above.
If you have any questions about or would like further information about the legal bases we rely on to collect and use your Personal Data, please contact us at email@example.com.
Rights Under the General Data Protection Regulation
If you are located in the EU, Switzerland, or the United Kingdom, you have the following rights in respect of your Personal Data that we hold:
– Right of access. The right to obtain access to your Personal Data.
– Right to rectification. The right to obtain rectification of your Personal Data without undue delay where that Personal Data is inaccurate or incomplete.
– Right to erasure. The right to obtain erasure of your Personal Data without undue delay in certain circumstances, such as where the Personal Data is no longer necessary in relation to the purposes for which it was collected or processed.
– Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Data in certain circumstances, such as where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data.
– Right to portability. The right to portability allows you to move, copy, or transfer Personal Data easily from one organization to another.
– Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
If you wish to exercise one of these rights, please email us at firstname.lastname@example.org. You also have the right to lodge a complaint with your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Retention of Personal Data
We reserve the right to retain any Personal Data as long as it is needed to: (1) fulfill the purposes for which we collected the Personal Data; and (2) comply with applicable law.
Transfers of Personal Data
If you are located in the EU, Switzerland, or the United Kingdom, the Personal Data we collect may be stored and processed in any country in which we or our affiliates, suppliers, third party electronic payment processors, and/or agents maintain facilities, including, without limitation, the United States of America. The United States of America has not sought nor received a finding of “adequacy” from the EU, Switzerland, or the United Kingdom. We rely on appropriate safeguards and derogations for specific situations as set forth in applicable laws to protect Personal Data transferred from the EU, Switzerland, or the United Kingdom to third countries and international organizations.
Obligations to Data Protection Authorities (DPAs)
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at email@example.com or by mail using the details provided below:
Walk West, Inc.
Attn: Privacy Manager
1730 Varsity Drive, Suite 200
Raleigh, NC 27606