Privacy Policy

KITZ SCT America Corporation

Privacy Policy

 

Effective as of: [July 6, 2022]

Please read and review this Privacy Policy (this “Policy”) carefully as it contains important information about who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or regulatory authorities in the event that you have a complaint.

When you use our website, products, services, or other activities (the “Services”), we collect, use, and become responsible for certain personal information about you. Your use of our Services constitutes your consent to these practices.

  1. Key Terms. Below are key terms and definitions used in this policy:
    Term(s)Definition
    “We,” “us,” or “our”KITZ SCT America Corporation, its parent, its affiliates, and the KITZ Group
    Personal InformationAny information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

     

  2. California Consumer Privacy Act (the “CCPA”). This Policy is intended to comply with the California Consumer Privacy Act (the “CCPA”). Where applicable, the terms used in this Policy shall apply the meanings given in the CCPA, and the regulations of the California Attorney General implementing the CCPA, unless otherwise specifically defined.

 

The CCPA applies to all California residents who visit our website. California residents who visit our website are permitted to request information regarding:

  • The categories of Personal Information collected, sold, or disclosed by us;
  • The purposes for which categories of Personal Information collected by us are used;
  • The sources of information from which we collect Personal Information; and,
  • The specific Personal Information we have collected about you.

 

Furthermore, California residents are entitled to:

  • Opt-out of the sale or disclosure of your Personal Information, in some circumstances;
  • Opt-out of receiving marketing communications from us (although you may still receive administrative communications regarding our services)
  • Opt-in to any financial incentive programs we may offer, from time to time, related to the collection, sale, or deletion of your Personal Information; and,
  • Request deletion of your Personal Information by us and our service providers, in some circumstances.

 

Please see the “How to Exercise your Rights” and “How to Contact Us” sections for more information.

  1. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with particular consumer or household:
    Categories of Personal InformationSpecific Types of Personal Information Collected
    Identifiers (e.g., name, alias, account name, postal address, unique personal identifier, online identifier, Internet Protocol address, e-mail address, social security number, driver’s license number, passport number, or other similar identifiers)Full Name;
    Telephone number;
    E-mail address;
    Company name;
    Company address;
    Company website;
    Internet Protocol address;
    Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Full name;
    Telephone number;
    E-mail address;
    Company name;
    Company address;
    Company website;
    Company department;
    Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)Product purchase history with us;
    Requests for quotations;
    Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)Browsing history on website;
    Download history on website;
    Cookies;
    Geolocation dataApproximated location via Google Analytics;
    Professional or employment-related informationCompany name;
    Company department;

     

  1. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email, and via our website. However, we may also collection information:
    • From publicly accessible sources (e.g., public corporate records);
    • Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
    • From a third party with your consent (e.g., your bank);
    • From cookies on our website; and,
    • Via our IT systems, including, without limitation:
      • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems; and,
      • Any other relevant systems.

 

  1. How and Why We Use Your Personal Information. Under applicable data protection law, we can only use your personal information if we have a proper reason for doing so (e.g., compliance with legal and regulatory obligations; performance of our contract with you or to take further steps at your request before entering into a contract; for our legitimate interests or those of a third party; or, where you have given consent).

 

A “legitimate interest” is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

 

Below, we have explained what we use your personal information for and our reasons for doing so:

What we use your personal information forOur reasons
To provide products and services to youFor the performance of our contract with you, or to take steps at your request before entering into a contract (e.g., responding to request for quotations or technical specifications)
To prevent and detect fraud against you or the KITZ GroupFor our legitimate interests or those of a third party (i.e., minimizing fraud that could be damaging for us and for you)
Conducting checks to identify our customers and verify their identity;

Screening for financial and other sanctions or embargoes;

Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory agencies or bodiesTo comply with our legal and regulatory obligations
Ensuring business policies are adhered to (e.g., policies covering security and internet use)For our legitimate interests or those of a third party (i.e., ensuring we are in compliance with our own internal procedures so we can deliver the best service to you)
Operational reasons, such as improving efficiency, training and quality controlFor our legitimate interests or those of a third party (i.e., to be as efficient as we can so we can deliver the best service for you at the best price)
Statistical analysis to help us manage our business and our services (e.g., in relation to our financial performance, customer base, efficiency measures, and product range)For our legitimate interests or those of a third party (i.e., efficiency measures to deliver the best service to you)
Preventing unauthorized access and modifications to systemsFor our legitimate interests or those of a third party (i.e., prevent and detect criminal activity that could damage us or you);

To comply with our legal and regulatory obligations
Updating and enhancing customer recordsFor the performance of our contract with you, or to take steps at your request before entering into a contract;

To comply with our legal and regulatory obligations;

For our legitimate interests or those of a third party (e.g., ensuring we can effectively communicate with our customers about existing orders and new products)
Marketing our services to:
• Existing and former customers;
• Third parties who have previously expressed an interest in our services;
• Third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party (i.e., promote our business to existing and former customers)

 

  1. Promotional Communications. We may use your personal information to send you updates (via email, text message, telephone, or mail) about our products and services, including exclusive offers, promotions or new products and services.

 

We have a legitimate interest in processing your personal information for promotional purposes (see “How and Why We Use Your Personal Information”). This means that we do not usually need your consent to send you promotional communications. However, where consent is needed, we will first seek your consent separately and clearly.

 

Your personal information will be treated with the utmost respect, and will never sell your personal information to other organizations outside of the KITZ group for marketing purposes.

 

You have the right to opt out of receiving promotional communications from us at any time by:

  • Contacting us at info@kitzsctamerica.com; or,
  • Using the “unsubscribe” link in emails or “STOP” number in texts.

 

  1. Who We Share Your Personal Information With. We routinely share personal information with:
    • Our parents or affiliates, including companies within the KITZ Group;
    • Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses, and delivery companies;
    • Other third parties we use to help us run our business, such as marketing agencies or website hosts;
    • Third parties approved by you, including social media sites you choose to link to your account to or third-party payment providers;
    • Credit reporting agencies;
    • Our insurers and brokers; and,
    • Our banks.

 

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations upon service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors as it may relate to accreditation or the audit of our accounts.

 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

 

We may also need to share some personal information with other parties, such as potential buyers of a portion or all of our business, or while in the process of a company re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

 

  1. Personal Information We Disclosed for a Business Purpose. In the preceding twelve (12) months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
    • Identifiers (e.g., name, alias, account name, postal address, unique personal identifier, online identifier, Internet Protocol address, e-mail address, social security number, driver’s license number, passport number, or other similar identifiers);
    • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health information;
    • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
    • Internet or other electronic network activity (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement);
    • Geolocation data; and,
    • Professional or employment-related information;

 

  1. Personal Information We Sold for a Business Purpose. We have not sold and do not sell consumer’s personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

 

  1. Where Your Personal Information is Held. Information may be held at our offices and those of our parents, affiliates, third party agencies, service providers, representatives, and agents as described above (see “Who We Share your Personal Information With”).

 

  1. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing either our products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary to:
    • Respond to any questions, complaints, or claims made by you or on your behalf;
    • Show that we treated you fairly; or,
    • Keep records as may be required by law.

 

We will not retain your personal information for longer than necessary for the purposes set forth in this policy. Different retention periods apply for different types of personal information.

 

  1. Your Rights Under CCPA. Under the CCPA and certain other privacy and data protection laws, you may exercise the following rights, free of charge:
    Related ActivityYour Rights
    Disclosure of Personal Information We Collect About YouThe Right to Know:
    • The categories of personal information we have collected about you;
    • The categories of sources from which the personal information is collected;
    • The categories of third parties with whom we share personal information, if any, and,
    • The specific pieces of personal information we have collected about you.

    Please note that we are not required to:
    • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
    • Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or,
    • Provide the personal information to you more than twice in a twelve (12) month period.
    Personal Information Sold or Used for A Business PurposeThe Right to Know:
    • The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and,
    • The categories of personal information that we disclosed about you for a business purpose.

    You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt out of the sale of your personal information. Under the CCPA, a the “selling” or “sale” of personal data means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating (in oral, written, or electronic form) a consumer’s personal information by the business to another business or third party for monetary or other valuable consideration. We do not sell any personal information to any third parties.
    Right to DeletionSubject to exceptions set forth under “How to Exercise Your Rights,” on receipt of a verifiable request from you, we will:
    • Delete your personal information from our records; and,
    • Direct any service providers to delete your personal information from their records.

    Please note that we may not delete your personal information if it is necessary to:
    • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or, prosecute those responsible for that activity;
    • Debug to identify and repair errors that impair existing intended functionality;
    • Exercise free speech, ensure that right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
    • Comply with the California Electronic Communications Privacy Act;
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
    • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
    • Comply with an existing legal obligations; or,
    • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
    Protection Against DiscriminationYou have the right not to be discriminated against because you exercised any of your rights under the CCPA. This means we are prohibited from the following activities, without limitation, in connection with your exercise of those rights:
    • Denial of goods or services to you;
    • Charge different prices or rates for goods or services, including through the use of discounts and other benefits or through the imposition of penalties;
    • Provide a different level or quality of goods or services to you; or,
    • Suggest that you will receive a different price or rate for goods or services or a different level or quality of such goods or services.

    Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that different is reasonably related to the value provided to our business by your personal information.

 

California Civil Code § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us using the information contained in the “How to Contact Us” section.

 

  1. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. In addition to our own internal storage of your personal information, we also utilize WordPress for the collection of your information as part of your use of our website. We encourage you to visit WordPress’ privacy policy page at https://automattic.com/privacy/ for more information, and how you may contact WordPress to exercise your rights under the CCPA and any applicable privacy laws and regulations.

 

  1. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Policy, you may call, write, or e-mail to us, using the contact information provided below under “How to Contact Us”. Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a twelve (12) month period. When contacting us, you will need to provide us with:
    • Sufficient identifying information (e.g., your full name, address, and any customer or matter reference number);
    • Proof of your identity and address (e.g., copy of your driver’s license, passport, or a recent utility bill); and,
    • A description or statement identifying what right you wish to exercise and the information to which your request relates.

 

We are not obligated to make a data access or data portability disclosure if we are unable to verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

 

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

 

  1. Third Party Analytics. We work with third party analytics companies and advertisers as part of operation of our website. Specifically, we work with Google Analytics, who may provide similar opt-out mechanisms at https://policies.google.com/privacy?hl=en_US.

 

  1. Minors and Users Under 18 Years Old. Our website is not intended for minors. No one under the age of majority may provide any personal information to or on our website either on their own behalf or on behalf of a company or business. We do not knowingly collect personal information from minors. If you are under the age of majority, do not use or provide any information on our website on or through any of its features or links. If we believe we have collected or received the personal information of a minor, we will promptly delete that information. If you believe we may have any information from or about a minor, please contact us pursuant to our “How to Exercise Your Rights” section and “How to Contact Us” section.

 

  1. Redress of Grievances. If you feel that we are not abiding by this Policy, you should contact us immediately via our contact information under “How to Contact Us.”

 

  1. Changes to This Privacy Notice. From time to time, we may change this privacy notice. Any amendments, changes, or revisions to this Policy shall be posted to this page, and the changes are effective at the time of posting. By continuing to access or use the Services after such changes become effective, you agree to be bound by such revised Policy.

 

  1. How to Contact Us. Please do not hesitate to contact us by mail, e-mail, or telephone if you have any questions about this privacy policy or the information we hold about you. We may be contacted as follows:
    KITZ SCT America Corporation
    5201 Great America Pkwy, Suite 238
    Santa Clara, CA 95054
    info@kitzsctamerica.com

 

  1. Cookies. A cookie is a small piece of data (normally a text file) that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies, which are cookies from a domain different from the domain of the website you are visiting, for other business purposes (e.g., advertising and marketing). More specifically, we use cookies and other tracking technologies for the following purposes:
    • Strictly Necessary Cookies. These cookies are necessary for the website to function, and cannot be switched off in our systems. They are usually only set in response to actions made by you, which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site may not properly function. These cookies do not store any personally identifiable information.
    • Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitor move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site, and will not be able to monitor its performance.
    • Targeting Cookies. These cookies may be set through our site by any third-party partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not directly store personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
    Type of CookieCookie NameDurationPurpose
    Strictly Necessary Cookieswordpress_[hash]This cookie is used to store authentication details.
    wordpress_logged_in_[hash]SessionThis cookie is created after login to indicate that a user has logged in, and contains certain user information. Deleting this cookie will log the current user out.
    wordpress_test_cookieSessionThis is a cookie used to test if a cookie can be set, and checks if cookies are enabled on the browser to provide appropriate user experience. This cookie can be created, even if a user is not logged in.
    wp-settings-[user_id]1 yearThis is a customization cookie that is unique to the user. It is used to persist a user’s configurations and to customize the view of the site / interface.
    wp-settings-{time}-[user_id]1 yearThis is a cookie that identifies the time in which the above user-id was set. This is used to customize the site or interface.
    Performance CookiesGoogle Analytics Cookies

 

Under the CCPA, you have the right to opt-out of the sale of your personal information to third parties. We do not currently sell any personal data you provide to us either directly (e.g., voluntary submission through our website or by providing your personal information by email, mail, or telephone) or indirectly (e.g., cookies). You may contact us for further clarification about your rights as a California consumer.