Echo Engineering & Production Supplies, Inc. Privacy Policy

 

Last updated: May 14, 2021

 

1.    Introduction

At Echo Engineering & Production Supplies, Inc. (“we,” “us,” or “our”), we value your privacy. This privacy policy (the “Policy”) provides a comprehensive overview of how we collect, use, and share your Personal Information when you access our website, https://www.echosupply.com/ (our “Website”), and the various content, features, and services offered on, through, and in connection with the Website, including customer accounts, order processing, and literature requests (collectively, our “Services”).

 

The Services are owned and operated by Echo Engineering & Production Supplies, Inc. The purpose of this Policy is to inform you about the types of Personal Information we collect about you when you use our Services, how we may use that Personal Information, with whom and how we may share that Personal Information, and the choices you have regarding our use of that Personal Information.

 

By using the Services, you consent to and agree that we may collect, process, use, retain, share, and transfer your Personal Information as described in this Policy. This Policy supplements and is incorporated into our Terms of Use, which may be accessed here. By accessing, downloading, registering with, or otherwise using our Services, you agree to this Policy and our Terms of Use, including any updates thereto.

 

This policy DOES NOT apply to information that we collect offline, including over the telephhone or via email communication, or in person or to information you provide to or is collected by any third party.

 

If you have questions regarding this Policy please contact us through your account, email us at info@echosupply.com, call us at 888.echo.365 or 888.324.6365 or send mail correspondence to 7150 Winton Drive, Suite 300 Indianapolis, IN 46268.

 

2.    Personal Information We Collect

Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you, a particular consumer or device (collectively, “Personal Information”).

 

The Personal Information we collect is determined by the context of the service being accessed. For example, the Personal Information we collect may vary depending on whether you have submitted an inquiry via our “Leave a Message” form or subscribed to our updates. You may opt-out from these collections at any time by ceasing to use the Services.

 

Sources of Information We Collect Include

·      directly from you, for example, from forms you complete or orders you make on our Website and

·      indirectly, automatically from you via technology that automatically assesses your use of our Services, for example, your device or equipment, browsing actions, and patterns.

 

Categories of Information We Collect Include

·      identifiers;

·      personally descriptive information;

·      location;

·      professional or employment-related information;

·      financial information;

·      content of correspondence;

·      internet and network activity information; and

·      commercial information.

 

Information We Collect Directly includes

·      your profile and identity information including your name, company name, postal address, phone numbers, email address, username, alias, account number/name, EIN, SSN, TID number, tax VAT number, and employee ID number;

·      details of financial transactions including credit card and bank account numbers;

·      records and copies of your correspondence including the email address, fax number, or physical address from which the correspondence was sent;

·      other information you provide when completing forms, making orders, or responding to surveys;

·      commercial information including your company’s name, consumer and credit reports, officer contact information, contact information for your financial and trade references, and purchasing history;

·      employment history and other information you enter when applying for a career with us or while working for us;

·      your signature; and

This information is necessary for the legal relationship between you and us.

 

Additional Information We Collect Directly includes

·      demographic information including your date of birth;

·      protected class information including your gender; and

·      inferences drawn from any of the above information.

This information is not necessary for the legal relationship between you and us.

 

Information We Collect Automatically Includes

·      real-time geographic location information about the location of your device;

·      your search queries on the Website including material and pages viewed;

·      name of your internet service provider;

·      information on the website you have visited us from;

·      information related to your social media account if you link the Website or our Services to your social media account;

·      the IP address assigned by your internet service provider;

·      requested files, amount of data transferred, downloads/files exported;

·      information on the pages of our Website that you visit, including date and time;

·      usage data including traffic data, number of bytes transferred, number of clicks per visit, logs,  and other communication;

·      device information including your internet connection, the device’s unique device identifier (UDID), MAC address, Internet Protocol (or IP) address,  sequence information, operating system, browser type and language, domain name system requests, mobile network information, and the device’s telephone number;

·      hypertext transfer protocol headers;

·      application client and server banners;

·      operating system fingerprinting data;

·      behavioral tracking, including information about your activities over time and across third-party websites, apps, or other online services; and

·      stored information files including metadata and other information associated with other files stored on your device such as, for example, photographs, audio and video clips, personal contacts, and address book information; and

·      inferences drawn from any of the above information.

This information is not necessary for the legal relationship between you and us.

 

We also keep track of how you use and interact with our Services through the use of cookies and other tracking technologies as listed below. 

·      Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

·      Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

·      Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and to gather other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

·      Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.

·      GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.

·      Do Not Track Signals. Do Not Track (“DNT”) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with a service on the page. For details, including how to turn on DNT, see www.donottrack.us. Because there currently is not an industry or legal standard recognizing or honoring DNT signals, we do not respond to them at this time.

·      Social Media Widgets. The Website may contain links to our accounts on Twitter, Facebook, Instagram, LinkedIn, Youtube, or other social media platforms. Clicking on any such link means that the respective platform may receive information indicating that you visited the platform from our Website. If you are currently logged in to your account on a particular platform, that platform may link this information to your account.

·      Keystrokes and Cursor Movement. We use Lucky Orange and other analytics services to keep track of and/or collect your keystrokes (but not the specific information entered) and cursor movements when you visit our Website, but this information is anonymous and, at the time of collection, we do not directly associate or attempt to associate this information with you as an identifiable individual. We use this information solely for the purpose of improving our Website and our customers’ user experience (e.g., improving navigation, readability, etc.).

·      Analytics Software. We use Google Analytics, Hotjar, and other web analysis service. These services use cookies to track your use of our Services and generate reports for us. Information is generated by the cookie regarding your use of our Services and is usually transmitted to and stored on a server in the USA. The analytics service will use this information on our behalf to evaluate your use of our Services, to compile reports on the activities within the Website, and to provide us with other services related to your use of our Services. Also, a pseudonymous usage profile may be created on you from the processed cookie information. You may prevent the collection by Google of the information generated by the Google cookie and Google’s processing of such information by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en. To prevent Hotjar from collecting your data, visit their website https://www.hotjar.com/privacy/do-not-track/.

·      Salesforce Pardot. We use Pardot to facilitate lead generation and targeted marketing. Pardot uses behavioral tracking software and syncs with our customer relationship management solution. You may unsubscribe from emails sent to you through this service by clicking the “unsubscribe” button at the bottom of the email.

·      Google Ads Advertising. We may use Google Ads or other search engine or display network advertising independent of or on our Website and through our Services. We may share your Personal Information to create targeted advertising through there services. Google’s advertising requirements and principles are set forth here. They are put in place to provide a positive experience for users without selling your Personal Information.

 

 

Third-Party Information Collection

When you use our Services, certain third parties may use automatic information collection technologies to collect Personal Information about you or your device. These third parties may include

·      your browser provider;

·      advertisers, ad networks, and ad servers;

·      analytics companies;

·      your mobile device manufacturer; and

·      your mobile service provider.

 

These third parties may also use tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

 

Further, where links to the websites of other companies are available, we have no influence as to their function or content. As a result, we provide no guarantee nor assume any liability for the collection practices, tracking technologies, or website function and content of any third party. Any Personal Information accessed, collected, or otherwise used through these third-party collection practices, tracking technologies, and websites is always and solely the responsibility of the respective company. If you have any questions about a website, an advertisement, or other targeted content provided by a third party, you should contact the responsible provider directly.

 

3.    How We Use Your Personal Information

We use Personal Information that we collect about you or that you provide to us to

·      provide you with the Services and any other information, products, or services that you, an individual or entity acting on your behalf, or an individual or entity with whom or with which we have a business relationship request from us;

·      fulfill any other purpose for which you, an individual or entity acting on your behalf, or an individual or entity with whom or with which we have a business relationship provide the Personal Information;

·      notify you when updates to our Services are available and of changes to any products or services we offer or provide;

·      provide you with information or services that you request from us or information about services that may be related to your request from us and for other marketing, promotions and advertising (including interest-based advertising) purposes;

·      be consistent with any way we may describe when you provide the information;

·      prevent fraud and enhance security;

·      respond to requests from law enforcement or other governmental authorities;

·      comply with any applicable law or legal obligation; and

·      consider consumers for employment or employ consumers and

·      for any other purpose with your consent.

 

The usage information we collect helps us to improve our Services and to deliver a better and more personalized experience by enabling us to

·      estimate our audience size and usage patterns;

·      store information about your preferences;

·      speed up your searches; and

·      recognize you when you use the Services.

 

We may use the Personal Information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

 

4.    With Whom and Why We Share Your Personal Information

We will only share your Personal Information with third parties as described herein, within the scope of applicable law, with the appropriate consent, and when obliged to do so due to mandatory legal regulations (e.g., disclosure to external bodies such as law enforcement authorities in the United States).

 

Entities with whom we may share your Personal Information include

·      our subsidiaries and affiliates;

·      contractors and service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them such as, but not limited to, for credit card processing and electronic funds transfers, electronic billing systems, business intelligence/financial analysis, file sharing systems, document management systems, collaboration sites, accounting service providers, faxing, email, email management and security, Cloud storage, targeted advertising services, internet and network operations and security, information governance systems;

·      shipping companies;

·      consumer credit and background check providers;

·      a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred; and

·      the public, government, or other entity when it is aggregated such that it becomes non-personal information that does not identify any individual, thus removing it from the restrictions of this Policy..

 

We share your Personal Information with these entities

·      to fulfill the purpose for which you provide it;

·      with your consent and at your direction;

·      for any other purpose disclosed by us when you provide the information;

·      to enforce or apply our Terms of Use;

·      to conduct or evaluate business transactions in our legitimate interests including (i) if we purchase other businesses or their assets, (ii) if we sell our business or assets, or (iii) if we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, and your Personal Information is among the implicated assets;

·      as aggregated non-personal statistical data showing general usage patterns and statistics, interactions, and transactions with our Services;

·      if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers or others including by exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;

·      when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or other harm or in connection with an investigation of suspected or actual illegal activity including illegal activity perpetrated through the Services or using our name;

·      if it is necessary to protect the vital interests (life, health or safety) of a person; and

·      to respond to legal requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your Personal Information.

 

5.    Choices About How We Use and Disclose Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your Personal Information:

·      Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

·      Interest-Based Advertising. We do not control third parties’ collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal Information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (NAI) through their website, located at the time of this Policy at https://optout.networkadvertising.org/?c=1. You can opt out of receiving targeted ads from members of the Digital Advertising Alliance (DAI) through their website, located at the time of this Policy at https://youradchoices.com/#zone-preface1-wrapper. Additionally, you can set preferences for how Google advertises to you using the Google Ad Settings website or by using the Google Analytics Opt-out Browser add-on.

·      Email Marketing. We may periodically send you promotional materials or notifications related to our products or services. If you want to stop receiving promotional materials, follow the unsubscribe instructions at the bottom of each email. There are certain service notification emails that you may not opt-out of, such as notifications of changes to our Services, Terms of Use, or policies or to your account.

·      Google Analytics. You may prevent the collection by Google of the information generated by the Google cookie and Google’s processing of such information by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en.

 

6.    Data Retention Period

We store your information as long as it is necessary for the processing purpose in question or in accordance with our data retention policy. Please note that a number of legally imposed retention periods require data to be stored for extended periods. This relates in particular to commercial or fiscal retention obligations. Unless there are further retention requirements, the data will be routinely deleted after use.

 

In addition, we may retain the information if you have given us your permission to do so or in the event of legal disputes, we use the information as evidence within the statutory limitation periods.

 

7.    Data Security

The security of your Personal Information is important to us. We make commercially reasonable efforts to secure and protect the privacy, accuracy, and reliability of your Personal Information and to protect it from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We have implemented security measures consistent with industry standards, including the option for you to turn on two-factor authentication. As no data security protocol is impenetrable, we cannot guarantee the security of our systems or databases, nor can we guarantee that Personal Information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information including your Personal Information is provided by you at your own risk.

 

8.       Our Services Are Not For Children

Our Services are not intended for children under 18 years of age. No one under the age of 16 may provide any information to, on, or through the Services. We do not knowingly collect Personal Information from children under 18. If you are under 16, do not use or provide any information to, on, or through these Services or any of their features or provide any information about yourself to us, including, but not limited to, your name, address, telephone number, or email address. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at info@echosupply.com.

 

9.       Notice to California Residents

If you are a California resident (also referred to as a “Consumer”), the California Consumer Privacy Act (the “CCPA”) provides you with additional rights regarding our use of your Personal Information. This section is provided pursuant to the CCPA. Each capitalized term used, but not defined, in this section shall have the meaning given to such term in the CCPA. For residents of California only, the term “Personal Information,” as used in this Policy, shall have the meaning given to the term in the CCPA.

 

Explanation of Rights

This notice for California Residents does not apply to the Personal Information of California residents that we collect

·      which is  reflecting a written or verbal communication or a transaction between us and you, where you are acting as an independent contractor or as an employee, owner, director, officer, or contractor of a company or government agency and whose communications or transaction with us occurs solely within the context of our conducting due diligence regarding, or providing or receiving a product or service to or from such company or government agency; or

·      in the course of your acting as a job applicant to or an employee of our company to the extent that your Personal Information is collected and used by us solely within the context of your role, or former role, as a job applicant to or an employee of our company.

 

California residents have the right to (a) access a copy of their Personal Information held by us, (b) request deletion of their Personal Information held by us, and (c) opt-out of the sale of their Personal Information. However, we do not sale any Personal Information, as defined by California law. Thus, it is not necessary for you to opt-out of the sale of your Personal Information.

 

The categories of your Personal Information we collect are listed above in the section entitled “Personal Information We Collect.” The purposes for which the Personal Information is or may be used is described above in the section entitled “How We Use Your Personal Information” and in other sections of this Policy. The third-parties with whom we share or sell Personal Information and the purpose for doing so is described above in the section entitled “With Whom and Why We Share Your Personal Information.” The word “share” as used in this Policy includes the sale of Personal Information as defined under the CCPA.

 

Right To Access to Specific Information

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable Consumer request, we will disclose to you

·      the categories of Personal Information we collected about you;

·      the categories of sources for the Personal Information we collected about you;

·      our business or commercial purpose for collecting, sharing, or selling that Personal Information;

·      the categories of third parties with whom we share that Personal Information;

·      the specific pieces of Personal Information we collected about you (also called a data portability request) and provide a copy to you in an electronic or paper format; and

·      the categories of Personal Information, if any, we disclosed for a business purpose to a third party.

 

Deletion Request Right

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Consumer request, we will delete (and direct our Contractors and Service Providers to delete) your Personal Information from our (and their) records, unless an exception applies (as described below).

 

As permitted by CCPA we may delete your Personal Information by (a) permanently and completely erasing the Personal Information on our existing systems with the exception of archived or back-up systems; (b) de-identifying the Personal Information; or, (c) aggregating the Personal Information.

 

We may deny your deletion request if retaining the information is necessary for us or one of our Contractors or Service Providers to

·      complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

·      detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

·      debug products to identify and repair errors that impair existing intended functionality;

·      exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

·      comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);

·      enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

·      comply with a legal, regulatory or law enforcement obligation; or

·      make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable Consumer request to us by calling us toll free at 888.echo.365 (888.324.6365) or emailing us at info@echosupply.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Consumer request related to your Personal Information. You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. To be verifiable, the Consumer request must

·      provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person; and

·      describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. Making a verifiable Consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable Consumer request to verify the requestor's identity or authority to make the request.

 

Verification Process

Upon receiving a data access or deletion request from you, we will verify your identity based on the information we have on file for you. Upon verification of your identity, we will proceed to process your request (subject to the exceptions stated above).

 

Response Timing and Format

We endeavor to confirm receipt of your request within ten (10) days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing.

 

We will deliver our written response via email to the email address associated with you or, if we are unable to determine your email address, via mail.

 

Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Please note that this right does not apply to business-to-business customers, employment applicants, or independent contractors to us, or if the disclosure of Personal Information is for purposes consistent with the California resident’s reasonable expectations, when considering the circumstances.

 

Non-Discrimination

We will not discriminate against you simply for exercising your rights under the CCPA. In particular, if you exercise any such rights, we will not

·      deny you goods or services;

·      charge you different prices or rates for goods or services, including by refusing to grant discounts or other benefits, or imposing penalties;

·      provide you a different level or quality of goods or services; or

·      suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

10.   Nevada Privacy Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to info@echosupply.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

 

11.   Notice to Residents of Non-U.S. Countries

If you are a resident of a country other than the United States of America, in addition to the disclosures made in this Policy, you may have other rights granted to you by your home country. We will comply with the laws of your home country as it relates to your Personal Information.

 

Transfer of Personal Information

Our headquarters is in the United States. The Personal Information we or our service providers and contractors collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers and contractors have facilities around the globe, and certain Personal Information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers and contractors may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.

 

If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, transferring, processing, storing, and otherwise using your Personal Data outside of the country in which you reside. Your acceptance of this Policy or use of our Website or Services constitutes consent, either express or implied, to collect, use, and share your Personal Information as indicated herein.

 

12.   Notice to Residents of the European Union and United Kingdom

If you are a resident of the European Union or the United Kingdom (also referred to as a “Data Subject”), the General Data Protection Regulation (“GDPR”) provides you with additional rights regarding our use of your personal information. This section is provided pursuant to the GDPR. Each capitalized term used, but not defined, in this section shall have the meaning given to such term in the GDPR. This section describes how we collect, share, disclose, and process the Personal Data of residents of the European Union and United Kingdom. “Personal Data” means any information relating to an identified or identifiable natural person (referred to ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes all “Personal Information” referred to in this Policy.

 

Rights of European Union and United Kingdom Residents

If you are located in the European Union or the United Kingdom, you have certain rights regarding the Personal Data that we maintain about you, which in certain circumstances you will be able to exercise. The rights are as follows:

·      Access. You may request a copy of the Personal Data that we maintain about you.

·      Portability. If we maintain your Personal Data based on your consent or so that we can enter into or perform under a contract with you, you have the right to obtain your Personal Data from us that you consented to give us, that is necessary to enter into or perform the contract, or that is necessary to provide member benefits to you. We will give you your Personal Data in a structured, commonly used and machine-readable format.

·      Correction. If you believe your Personal Data is incorrect, you may request that we correct, amend or delete your Personal Data that is inaccurate or incomplete.

·      Deletion or Restriction of Processing. You may request that we erase or restrict the processing of your Personal Data.

·      Object to Processing. You may object to the processing of your Personal Data in certain circumstances when we process your Personal Data for the purposes of our legitimate interests.

·      Right to Complain. You have the right to file a complaint with a supervisory authority, in particular in the European member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your Personal Data infringes upon your rights.

·      Withdraw Consent. If we are processing your Personal Data based on your consent to do so, you may withdraw that consent at any time.

 

Some of these rights can be exercised online via your account. For example, you can review and modify certain information relating to your use of our Services and unsubscribe to email messages. If you are unable to manage your request via your online account, then please contact us at info@echosupply.com.

 

Collection of Personal Data

We only collect Personal Data that is reasonably necessary for us to provide our Services. Subject to applicable exceptions, we will obtain your Consent before collecting, using and disclosing your Personal Data for the specified purposes. In addition to circumstances in which you Consent to the use of your Personal Data, the Personal Data we collect may be used or processed where we have a legitimate interest in or other legal basis for processing such data. 

 

The categories of your Personal Data we collect are listed above in the section entitled “Personal Information We Collect.” The purposes for which the Personal Data is or may be used is described above in the section entitled “How We Use Your Personal Information” and in other sections of this Policy. Additionally, in some situations, the processing of Personal Data may be required for the operation of our Services or to provide you with information about our products and Services.

 

If we use Personal Data in ways other than described in this Policy, we will provide you with specific notice at the time of collection.

 

Sharing Personal Data

·      Disclosures to Affiliates. We may share your information, including your Personal Data, with our affiliates to understand and develop the demographic makeup of our members, provide you with offers from our affiliates, and coordinate the services that are offered and provided to you by us and our affiliates.

·      Disclosures to Service Providers. We also may share your Personal Data with our service providers and contractors who perform services and functions on our behalf to support our interactions with you including, for example, providing our products and services, processing your purchases, administering surveys or contests, or communicating with you. These entities are only allowed to process the Personal Data that we share with them in accordance with our express instructions and in compliance with your local law. Where it is necessary for Personal Data to be provided to a service provider or contractor in connection with providing a service to us, we will take reasonable steps to prevent the unauthorized use or unauthorized disclosure of your Personal Data.

·      Disclosures to Third Parties. With your consent, we may share your Personal Data with Third Parties for the purpose of providing or improving our Services to you. The Third Parties with whom we share or sell Personal Data and the purpose for doing so is described above in the section entitled “With Whom and Why We Share Your Personal Information.”

 

Processing Personal Data

We only process Personal Data when we have a legal basis to do so including

·      when you have consented to the processing of your Personal Data;

·      when processing is necessary to perform a contract with you or fulfil a request you have made;

·      when processing is necessary to comply with a legal obligation that applies to us; or

·      when processing is necessary for purposes that are in our legitimate interests and you have given any required explicit or implicit Consent to such processing, including protecting the security of our Services, improving the functioning of our Services, or providing you with information about products in which you have expressed interest.

 

If we need to process your Personal Data to fulfil or enter into a contract with you, failure to provide that Personal Data will mean that we cannot perform or enter into a contract with you. If we collect your Personal Data for one purpose and need to process it for second purpose, we will provide you with additional information regarding this secondary purpose to ensure fair and transparent processing before we engage in further processing.

 

13.   Changes To Our Privacy Policy

We may modify this Policy from time to time. The most current version of this Policy will govern our use of your Personal Information and is located at https://www.echosupply.com/privacy-policy. We will notify you of material changes to this Policy by posting a notice at the Website or by emailing you at an email address associated with you, if applicable.