We may ask you to provide us with, or you might submit via the Site, personally identifiable information, which is information that identifies an individual personally, such as one’s first and last name, telephone number, e-mail address, geolocation data, educational background information and employment history (“Personal Information”). We may collect this Personal Information through various forms and in various places on the Site, including account registration forms, “contact us forms”, or when you otherwise upload data to and interact with the Site.
In addition to any Personal Information or other information that you choose to submit to us via the Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. To the extent we associate Usage Information with Personal Information we collect directly from you on the Site, we will treat it as Personal Information.
This Usage Information may include:
Tracking Technologies:
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the Site. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Site’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).
Tracking Technologies Usage:
We may use Tracking Technologies for a variety of purposes, including:
Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity and improve security.
Performance-Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site.
Functionality-Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you sign-in to our Site or keeping track of our specified preferences, including in terms of the presentation of content on our Site.
Targeting-Related. We may use Tracking Technologies to deliver content relevant to your interests on our Site and third-party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
Tracking Technologies Choices and Consent:
We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above. Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary.
We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.
Third Party Tracking and “Do Not Track”:
There may be other Tracking Technologies now and later devised and used by us in connection with the Site. Further, third parties may use Tracking Technologies in connection with our Site, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Site and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
We may, from time to time, supplement the information we collect directly from you on the Site with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the Site, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.
The Site may include functionality that allows certain kinds of interactions between the Site and a third-party website or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you register with the Site, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Site, or otherwise link accounts. If we offer and you choose to use this functionality to access or use our Site, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Site. In addition, we may provide third-party sites’ interfaces or links on the Site to facilitate your sending a communication from the Site. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Senné may not control or have access to your communications through these third parties. Further, when you use third-party websites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Site.
We may use your Personal Information or Usage Information that we collect about you: (1) to provide you with information or services or to process transactions that you have requested or agreed to receive, including for job opportunity consideration as a result of an online employment application or for providing general information about Senné’s services in response to a request submitted online; (2) to provide you with information via email about product or service offerings from Senné, Senné’s clients or Senné’s partners on an ongoing basis, unless you opt out of receiving such emails; (3) to enable you to participate in a variety of the Site’s features; (4) to send promotional or marketing emails to you on behalf of the other businesses or organizations; (5) to process your account inquiry, including verifying your information is active and valid; (6) to improve the Site, to create new service offerings, to customize your experience on the Site, or to serve you specific content that is most relevant to you; (7) to contact you with regard to your use of any of the Site and, in our discretion, changes to the Site and/or any of the Site’s policies; (8) for internal business purposes; and (9) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
Please note that information submitted to the Site via a “contact us” or other similar customer inquiry function may not receive a response.
We will not share Personal Information with third parties for their direct marketing purposes. We may, however, share non-Personal Information, such as aggregated user statistics and browsing behavior information, with third parties. We may share the information we have collected, including Personal Information, as disclosed at the time you provide the information and as described below or otherwise in this Privacy Policy. Senné may also disclose Personal Information as follows:
You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
We may use third-party vendors to perform certain services on behalf of us or the Site, such as hosting the Site, designing and/or operating the Site’s features, tracking the Site’s activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to Personal Information. We are not responsible for those third-party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third party’s opt-out options.
To the fullest extent permitted by applicable law, we may also disclose Personal Information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Senné or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, the User Agreement or other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.
We may share Personal Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
Certain laws, including the EU General Data Protection Regulation (“GDPR”), require that we inform applicable individuals of the legal bases for our use and other processing of personal information. Pursuant to the GDPR (and other relevant laws), we process personal information for the following legal bases:
With your consent: where we have your consent (the GDPR (where it applies)) and other applicable laws give you the right to withdraw your consent, which you can do this at any time by contacting us using the details at the end of this privacy notice. In some jurisdictions, your use of the Site may be taken as implied consent to the collection and processing of personal information as outlined in this privacy notice.
In addition, we may process your personal information where necessary to protect the vital interests of any individual.
The Site contains content that is supplied by third parties, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you. In addition, when you are on the Site you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Site onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you or others, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Site and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Site may allow you to review, correct or update Personal Information you have provided through the Site’s registration forms or otherwise, and you may provide registration updates and changes by contacting us. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Site, information that you remove may persist internally for Senné’s administrative purposes. You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your Site account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Attention: Privacy Officer, “The Senne Company Inc.”, 1 Lewis Wharf, Boston MA 02110; By e-mail: [email protected].
Our Site is operated in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. If you are located, for example, in European Economic Area or Switzerland, your personal information will be transferred to the United States and possibly to other jurisdictions (e.g., to the location of a property for which you have requested information), which may not provide the same level of protection under your local data protection laws. In such cases, we rely on suitable personal information transfer safeguards. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.
We understand the importance of protecting children’s privacy in the interactive world. The Services are not intended or directed to children under the age of 16, and we do not knowingly collect any personal information, or knowingly track the use of our Services, from children. If we have actual knowledge that personal information about a child under 16 years old has been collected, then we will take appropriate steps to try and delete such personal information.
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our California Residents Privacy Notice.
The GDPR (where applicable), gives data subjects the following rights regarding their personal information:
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for:
We can continue to use your personal information following a request for restriction, where:
We endeavor to incorporate commercially reasonable safeguards to help protect and secure Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.
We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Site indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.