Last updated: 07/18/2019
DicksonData.com Privacy Statement
Dickson, Inc. (“Dickson”) is committed to protecting the data of individuals visiting the Dickson website (“Website”) or individuals using Dickson products or related services (collectively, “Services”). This Dickson Privacy Statement (“Privacy Statement”) sets out how we collect, use, and share your personally identifying information (“Personal Data”) in connection with your use of the Website and Services or through other interactions between you and Dickson (for example, employment applications, sales or marketing communications). Additionally, this Privacy Statement outlines each the rights of persons located in the European Economic Area (“EEA”) or Switzerland with respect to Personal Data under EEA and Swiss data protection laws.
1. Collection and Use of Data
(a) Data Collection
(i) Personal Data
We may collect the following Personal Data:
- From You: First and last name, mailing address, telephone number, email address, professional title, company name, credit card number, Dickson account username and password, and any Personal Data you provide through our technical support forum.
We also collect resumes from individuals pursuing employment opportunities with Dickson.
- Other Information: IP address.
(ii) Technical Data
In addition, in connection with the use of the Services or when you post information to our application programming interface (“API”), we may collect certain Technical Data such as time series data you post to our API, operating system configurations and data, information about your application and operating environment (i.e., version data, configurations, etc.), log files and codes samples for certain classes of errors, and other similar data related to your application or use of our Services. Technical Data does not include Personal Data.
(iii) Anonymous Data
Dickson may create Anonymous Data by excluding data elements that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve site navigation. Dickson reserves the right to use for other purposes and to disclose Anonymous Data to third parties in its discretion.
If you provide feedback on any Services, we may use such feedback for any purpose.
When you submit or make available Personal Data or Technical Data through our Website or Services, you agree to the terms, including the processing of such data, as outlined in this Privacy Statement.
(d) Data Use
When you communicate with Dickson or use the Website or Services, we will collect and process Personal Data and Technical Data for several different purposes, including:
- To provide the Services;
- To provide technical support for the Services;
- To keep you up-to-date regarding new features, services, and promotions offered by Dickson;
- To pursue the legitimate business purposes of Dickson, including providing Services, responding to employment inquiries and preventing fraud or other misconduct;
- To analyze, review and improve the Services, Website, and interactions with You;
- For internal recordkeeping requirements;
- To comply with any legal and regulatory requirements; and
- To protect and defend our rights and property, including by way of legal proceedings.
Provision of Personal Data is required to use the Website or Services, if you do not provide Personal Data for processing in connection with the purposes listed, you may not have full access to features of the Website or Services.
(e) Data Sharing
Dickson may share your Personal Data with third parties during the course of our business as set out below:
- Service Providers: To our service providers to assist in providing you with the Services you have requested, or who maintain the Website or our technical support chat service, or who provide us with other, related services in the course of our business.
- Payment Processors: To our payment processors when you purchase Services.
- Partner Companies: To third parties that create items used in Dickson Services or assist in providing Services.
- Other Parties When Required by Law or Regulatory Authority: We may be required by statute, court order or other government or regulatory mandate or compulsion to disclose information in order to comply with applicable law.
- Other Parties Where We Believe Necessary: We may also disclose your information (i) where we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; (ii) in the good faith belief that disclosure is otherwise necessary or advisable; or (iii) where we believe it will help to protect Dickson or to enforce any legal rights.
No personal data is shared with any third party for their own marketing purposes.
(f) Cross-Border Transfers
Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States (US), to fulfill any purposes outlined in this Privacy Statement. Although the data protection laws in these countries may vary, we will endeavor to ensure the Personal Data will be afforded no less protection due to its transfer. We utilize Model Clauses between our EU and US affiliates and with applicable third parties to effectuate the secure transfer of your Personal Data to third countries.
By agreeing to this Privacy Statement, you expressly consent to the processing of your Personal Data in any jurisdiction, including, without limitation, the United States, in accordance with this Privacy Statement.
(g) Data Retention
We will retain your Personal Data only for so long as it is reasonably necessary to provide you with requested Services or for our internal business purposes unless a different timeline for retention and destruction is required by applicable law.
(h) Note Concerning Children
Dickson does not intentionally collect Personal Data about visitors who are under the age of 13. In the event Dickson learns we have collected Personal Data from a child under the age of 13, we will promptly delete such data.
2. Data Security
We maintain an information security policy that, taking into account the nature of the data processed and in accordance with a risk-based approach, includes technical and organizational measures intended to protect the security, confidentiality, and integrity of Personal Data.
3. External Links
The Website may contain links to third party sites or other apps that are not owned or operated by Dickson. This Privacy Statement only applies to the Website and does not apply to any third party sites. Dickson is not responsible or liable for the privacy practices of other third party sites.
4. Changes to Privacy Statement
Dickson may update this Privacy Statement from time to time as it deems necessary in its sole discretion. If there are material changes to this Privacy Statement, we will provide notice where and in the manner required by applicable law, including but not limited to, by email and at www.dicksondata.com. Your continued use of the Website or Services and continued interaction with Dickson after notice of any amended Privacy Statement shall constitute your agreement to be bound by such changes. Any changes to this Privacy Statement take effect immediately after being notified by Dickson.
5. Privacy Statement for Data Subjects Located in the European Economic Area or Switzerland
(a) Applicability of EEA and Swiss Data Protection Laws
Dickson is a global brand and thus may conduct business with individuals from within the EEA or Switzerland. In order to carry out business with these individuals, we may transfer Personal Data from individuals (“Data Subjects”) located within the EEA or Switzerland (“EEA Personal Data”). EEA Personal Data may be collected by us when provided by the Data Subject, in communications with Dickson or when using the Website or Services.
(b) Lawful Grounds to Process and Obtain Consent
Data Subjects whose EEA Personal Data is processed based on their consent may withdraw consent at any time where consent is the sole lawful basis for processing his/her information. Should a Data Subject withdraw consent for processing or otherwise object to processing that impedes Dickson’s ability to comply with applicable regulations, a Data Subject may be unable to avail him/herself of the Services. The decision to withdraw consent will not affect the lawfulness of processing based on consent before its withdrawal.
(c) Data Subjects’ Rights
All individuals whose EEA Personal Data are held by Dickson have the right to:
- ask what information Dickson holds about them and why;
- ask for a copy of such information or access to such information;
- be informed how to correct or keep that information up to date; and
- be informed on how Dickson is meeting its data protection obligations.
Furthermore, for EEA Personal Data, Data Subjects have the right to:
- ask for a copy of such information to be sent to a third party;
- ask for your Personal Data to be erased if possible and required under the General Data Protection Regulation (“GDPR”) or applicable Swiss law;
- ask for processing of your Personal Data to be restricted if possible and required under GDPR or applicable Swiss law;
- object to processing of your Personal Data if possible and required under GDPR or applicable Swiss law;
- object to automated decision-making where applicable; and contact a supervisory authority in the EEA or Switzerland, as applicable, to lodge a complaint regarding Dickson’s processing of your EEA Personal Data.
(d) Automated Decision-making
Dickson does not engage in automated decision-making.
(e) Note Concerning Children Located in the EEA or Switzerland
Dickson does not intentionally collect Personal Data about Data Subjects who are under the age of 16. In the event Dickson learns we have collected Personal Data from a Data Subject under the age of 16, we will promptly delete such data.
6. Dickson Contact Information for Questions Regarding the Privacy Statement
If you have questions about this Privacy Statement, you may contact the Global Controller at firstname.lastname@example.org or write to us at:
Attn: Accounting Department
930 South Westwood Avenue
Addison, IL 60101 USA