Note: When we process Personal Data on behalf of a customer through our Services, we act as the customer’s data “processor” under the European Union General Data Protection Regulation (“GDPR”). Our customers may provide their own privacy disclosures under applicable data protection law and we encourage you refer to those disclosures for more information about their practices. If your business is subject to the GDPR and you would like to enter into a data processing agreement with us relating to personal data for which you are the GDPR “controller,” please contact us.
Personal Data Disclosures
When we use the term “Personal Data” in these European Privacy Disclosures, we mean any information relating to an identified or identifiable natural person.
Legal Bases for Processing
We use the Personal Data we collect about you in the following ways and rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
We use the Personal Data we automatically collect about you in the following ways and rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
You are not required to provide Personal Data to us, but we do rely on your Personal Data to provide certain of our services and products. For example, we need your Personal Data to facilitate and deliver an order that you request. If you choose not to provide us with your Personal Data, we may not be able to provide you with a service or product you request.
We retain Personal Data about you for as long as is necessary for the purposes set out in these European Privacy Disclosures, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.
The criteria used to determine the period for which Personal Data about you will be retained varies depending on the legal basis under which we process the Personal Data:
In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the Personal Data, as well as the potential risk of harm from unauthorized use or disclosure of your Personal Data.
International Data Transfers
We may transfer Personal Data about you outside the EEA, and when we do so, we rely on appropriate or suitable safeguards recognized under the GDPR, including adequacy decisions and standard contractual clauses.
We may transfer Personal Data about you to countries that the European Commission has deemed to adequately safeguard Personal Data by adopting European Commission Adequacy Decisions.
Standard Contractual Clauses
The European Commission has adopted Standard Contractual Clauses, which provide safeguards for Personal Data transferred outside of the EEA. We may use these Standard Contractual Clauses when transferring Personal Data from a country in the EEA to a country outside the EEA that has not been deemed to adequately safeguard Personal Data. You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.
Your Privacy Rights
You have the following rights in relation to your Personal Data (subject to certain limitations at law):
Please note that if the exercise of these rights limits our ability to process Personal Data, we may not be able to provide our products or services to you, or otherwise engage with you going forward.
Right to Withdraw Consent
Where we rely on your consent for processing of your Personal Data, as identified in the Legal Bases for Processing section above, you also have the right to withdraw your consent to such processing. You may withdraw your consent at any time by contacting us using the contact details at the end of these European Privacy Disclosures.
To submit a request, please contact us as set forth in the Contact Us section below. We may need to verify your identity before processing your request, which may require us to obtain additional Personal Data from you. In certain circumstances, we may decline a request to exercise the rights described above.
Right to Lodge a Complaint
If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority). If you are based in the EEA, information about how to contact your local data protection authority is available here. However, we encourage you to first reach out to us by using the contact details set out in the Contact Us section below so that you have an opportunity to address your concerns directly and so that we may find a solution together before you do lodge a complaint.
Updates to These Disclosures
We may update these European Privacy Disclosures from time to time. When we make changes to these European Privacy Disclosures, we will post the updated notice on our website. If we make material changes to these European Privacy Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.