Updated: March 31, 2020
Acknowledgement and Consent
Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (the foregoing in this sentence being referred to as “De-Identified Personal Information”).
Individuals Under the Age of 18
We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. No one under age 18 should provide any Personal Information to us. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.
Personal Information We Collect
We collect several categories of Personal Information from and about you, namely,
Specific Items of Personal Information
Internet or other
From What Sources Do We Collect Personal Information?
If you submit information regarding employment via our career Website portal, we may obtain information from third parties about employment as part of a background check, among other information, as part of the application process.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.
- Behavioral Tracking. We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including, but not limited to, by enabling us to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Website; (c) speed up your searches; and/or, (d) recognize you when you return to our Website.
The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.
Cookies (or browser cookies)
A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer (Internet Explorer, Firefox, Safari or Google Chrome).
Different types of cookies which have different purposes are used on our Website.
These cookies are essential to allow you to browse our Website and use its functions.
These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Websites from their site. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of sites that are not under our control.
Local Storage Cookies. Certain features of our Website may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Local storage 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 for 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 and research.
GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
IP Address. Our servers automatically record certain log file information reported from your browser when you access the Services. These server logs may include information such as which pages of the Service you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Services. These log files are generally deleted periodically.
Information We Collect from Third Parties
We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website.
- Third Party Services. If you link, connect, or login to your account with a third party social media service (e.g., Facebook, WeChat), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Employment and Background Information. For job applicants in the United States, to the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions or sex offender registrations.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Website through partnerships, or about your experiences and interactions from our partner ad networks.
Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies 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 and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information on how to opt-out of third-party advertiser tracking mechanisms, please click here.
Google AdSense Advertising. We use Google AdSense Advertising (or other search engine or display network advertising) on our website. Google’s advertising requirements can be summed up by Google’s Advertising Principles (click for link to Google’s website). They are put in place to provide a positive experience for users. We have implemented the following: (a) Remarketing with Google AdSense and (b) Google Display Network Impression Reporting.
We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.
How We Use Your InformationWe use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
- To present our Website and its contents to you.
- To provide you with information on products or services that you request from us.
- To provide you with the services that you have requested.
- To send you emails and newsletters with product, service, company, and other information.
- To provide you with information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you.
- To respond to your questions or other requests.
- To contact you with regard to the Website and to send important notices, such as communications about our Services, your account or changes to our terms, conditions, and policies..
- To process any applications, changes to your account information.
- To process other information or Personal Information that you submit through this Website.
- To notify you about changes to our Website, our policies, terms or any products or Services we offer or provide though it.
- To allow you to participate in interactive features on our Website.
- To ask for ratings and reviews of our Website, Services, and/or products.
- To request your participation in surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and Services.
- For examination or event registration, scheduling, event attendance, administration and related purposes.
- To serve relevant information to you when you visit our Website or other third-party sites (including social media platforms).
- To contact you about our own and third-parties’ products and services that may be of interest to you. If you do not want us to use your information in this way, please either check the relevant box located on the form on which we collect your data (the order form) or adjust your user preferences in your account profile).
- To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends and measuring demographics and interests.
- For internal purposes, such as Website and system administration or internal audits and reviews.
- For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
- To operate, maintain, and provide to you the features and functionality of the Services.
- To provide statistics about the usage levels of the Website and other related information to reputable third parties, but these statistics will not include information which will allow you to be identified.
- To notify you of data privacy incidents or provide you with legally required information
- To fulfill any other purpose for which you provide it.
- In any other way we may describe when you provide the information.
How We Share Your Personal Information
We may disclose your Personal Information, in whole or in part, with third parties for the purpose of introducing, providing, or improving our Services to you, who perform services on our behalf, or for our own marketing purposes. We may or do disclose Personal Information to the following types of third parties, and for one or more the following purposes:
- Hosting providers for the secure storage and transmission of your data
- Identity management providers for authentication purposes
- Database software providers for the management and tracking of your data
- Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
- Technology providers who assist in the development and management of our Website
- Advertising partners, including social media providers, for the delivery of targeted advertisements
Disclosures to Service Providers: We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide support services on our behalf. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
We DO NOT disclose or share your Personal Information with any third parties for which we receive any monetary or other valuable consideration; in other words, we do not sell your Personal Information, period.
Disclosure of De-Identified Personal Information: We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services, and for any other purpose we deem appropriate.
Your Consent to Disclosure/Transfer/Sale of Your Personal Information: You consent to our disclosure of your Personal Information and other information to a potential or actual buyer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) of any or all of our rights to your Personal Information and your consents, in whole or in part, and other information, with or without notice to you and without your further consent.
Data Transfer/Access Outside of the United States
We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain 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 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 located in the European Economic Area (“EEA”) or Switzerland, we provide adequate protection for the transfer of Personal Information to countries outside of the EEA or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses. We may also need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.
If you are a resident of country other than the United States, you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of service providers who have special access rights to our systems, and who are required to keep the information confidential. Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safer.
The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as your user account is active, or as long as you are a customer or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
Privacy Rights for California Residents Only
Online Privacy Protection Act (“CalOPPA”)
California residents are entitled to ask us annually for a notice identifying the categories of Personal Information (if any) which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom we have shared such information during the immediately preceding calendar year. You also have the right to request that we revise your Personal Information on record. To make such a request, please contact us with “Request for California Privacy Information” in the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. To obtain information about CalOPPA, the CalOPPA website here.
How We Respond to Do Not Track (DNT) Signals.
Do Not Track Signals. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take. We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
Behavioral Tracking: Please see the section above on this topic.
California Consumer Rights Privacy Notice
California Consumer Privacy Act of 2018 (“CCPA”) Privacy Notice for California Residents. If you are a California resident, California law provides you with additional rights regarding our use of your Personal Information.
Starting January 1, 2020, California residents have the right to (a) access a copy of their Personal Information held by us, and (b) request deletion of their Personal Information held by us. These rights can be exercised by completing and submitting the webform available here.
This “California Consumer Rights Privacy Notice section does not apply (at least until January 1, 2021) 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 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, an employee of our company.
WE DO NOT SELL (AS THAT TERM IS DEFINED IN THE CCPA) YOUR PERSONAL INFORMATION, PERIOD.
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 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).
- If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
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 service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) 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.
- 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 our webform available here, or sending an email to us at firstname.lastname@example.org. 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 also make a verifiable Consumer request on behalf of your minor child. You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. The verifiable 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.
- 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 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.
Email Verification Method: Upon receiving a data access or deletion request from you we will send an email to you at the email address we have for you on file. The email will ask you to respond to verify you as the Consumer making the request. Upon receipt of your verification we will match your information to that which is in our file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above).
Webform Verification Method: When you submit a request using our webform (available here) we will match the information you submitted with the information we have for you on file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above). We may not be able to comply with your request if (a) we are unable to verify your request, (b) if we are unable to match you with information in our database, or (c) if an exception under the law exists exempting us from complying with your request.
Response Timing and Format
We will 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.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request's 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 submission’s circumstances.
We will not discriminate against you simply for your exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including by refusing to gran 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.
Online Privacy Protection Act (“CalOPPA”).
Under California Civil Code Sections 1798.83-1798.84 (known as the “Shine the Light” law), California residents are entitled to ask us annually for a notice identifying the categories of Personal Information (if any) which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom we have shared such information during the immediately preceding calendar year. You also have the right to request that we revise your Personal Information on record. To make such a request, please contact us with “Request for California Privacy Information” in the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. To obtain information about CalOPPA, the CalOPPA website here.
How We Respond to Do Not Track Signals. CalOPPA requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to or honor them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to our Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Service, the Website, and/or the Mobile App to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.
Kurita America Inc.
12270 43rd Street NE
St. Michael, MN 55376