A. NOTICE TO CALIFORNIA RESIDENTS
To the extent any California data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the rights that California residents may have, and how they can exercise those rights. This notice applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We provide the supplemental section below to comply with the California Consumer Privacy Act [as amended by the California Privacy Rights Act (referred to collectively hereinafter as CCPA)] and any terms defined in the CCPA have the same meaning when used below.
This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals, as such information practices may be found in our Employee Privacy Notice and Prospective Employee Privacy Notice.
1. Your Rights under CCPA
- Right to Know and Access Specific Information. You have the right to request that we disclose certain information to you about our collection and use of your Information over the past twelve (12) months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you, to the extent permitted by law:
- The categories of Information we collected about you, and whether we sell or share your information to third parties.
- The specific pieces of Information we hold about you.
- The categories of personal information sold within the last 12 (twelve) months.
- The categories of sources from which Information about you is collected.
- Our business or commercial purpose for collecting, selling, or sharing your Information.
- The categories of third parties with whom your Information is sold, shared, or disclosed for a business purpose.
You have the right to request that the Information described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability”).
- Deletion Request Rights. You have the right to request that we delete the Information that we collected from you, subject to certain exceptions. To the extent that we can delete your Information, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Information, unless an exception applies.
- Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your verifiable consumer request, we will use commercially reasonable efforts to correct your personal Information.
- Sale and Sharing of Personal Information and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:
- Sale of your Information.
- Sharing of your Information for cross-context behavioral advertising.
The use of online tracking technologies may be considered a “sale” or “sharing” under California law. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under California law, you may opt out of these online tracking technologies by submitting a request
here or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC).
- Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the ways we use and disclose your sensitive personal Information (as defined by CCPA) to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or and as authorized by law.
- Right to Non-Discrimination. You have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We may not, and will not, treat you differently because of your data subject request activity. As a result of your data subject request activity, we may not and will not deny goods or Services to you, charge different rates for goods or Services, provide a different level quality of goods or Services, or suggest that we would treat you differently because of your data subject request activity.
- Right to Disclosure of Direct Marketers. You have a right to the categories and names/addresses of third parties that have received personal Information for their direct marketing purposes upon simple request, and free of charge.
You may make an authenticated consumer request exercising your Right to Know and Access Specific Information including Right to Know what Personal Information is being Sold or Shared or under the CCPA twice within a twelve (12) month period. To exercise the rights described above, see the
Exercising Your Rights section below.
2. Authorized Agent
You may use an authorized agent to submit verifiable consumer requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant to California Probate Code sections 4000 to 4665. We may deny a request from an authorized agent that does not submit proper verification proof.
3. Notice of Financial Incentive
As an incentive for providing us with your Information, you may receive a financial benefit in the form of an email coupon, discount, rebate, free sample, promotions, or other similar reward that will be sent to you. This discount may constitute a financial incentive under the California Consumer Privacy Act (“Financial Incentive”). The categories of personal Information required for us to provide the Financial Incentives include personal identifiers such as full name and contact information including email address as well as personal and demographic information you choose to provide.
To offer these discounts, we may track your personal Information, such as purchase history and other demographic data. You have the right to withdraw from the Financial Incentive at any time by submitting a request to dataprivacyoffice@aei.com. Please note that if you request deletion of part or all your personal Information, that could affect your ability to qualify for the discount.
4. Additional Information
To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
B. NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND THE UK
This section applies only to individuals coming to our Services from within the European Union (EU), the European Economic Area (EEA), and the UK, and only if we collect through the Services any Information from you that is considered “Personal Data,” as defined in the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.
Personal Data includes any information relating to an identified or identifiable natural person, who could be identified either directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one (1) or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person (which may include some or all your Information as defined in this Privacy Policy).
1. Identity and Contact Details of Controller and EU Representative Unless otherwise stated, we are the Data Controller for the Information we process.
Contact Details:
Lisa Rehkugler
Managing Consultant Data Privacy
Email: lrehkugler@intersoft-consulting.de
2. Your Data Protection RightsTo the extent the GDPR and Data Protection Act 2018 apply, and we hold your Information in our capacity as a Data Controller as defined under those laws, you may request that we:
- Restrict the way that we process and share your Information;
- Transfer your Information to a third party;
- Provide you with access to your Information;
- Remove your Information if no longer necessary for the purposes collected;
- Update your Information so it is correct and not out of date; and/or
- Object to our processing of your Information.
You may also revoke your consent for processing of your Information. If you wish to object to the use and processing of your Information or withdraw consent to this Privacy Policy, you can contact us in the following ways:
Lisa Rehkugler
Managing Consultant Data Privacy
Email: lrehkugler@intersoft-consulting.de
The requests above will be considered and responded to in the time period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional Information from you to confirm your identity in responding to such requests.
You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us at:
Lisa Rehkugler
Managing Consultant Data Privacy
Email: lrehkugler@intersoft-consulting.de
3. Lawful Basis for Processing Your InformationThe lawful basis for our processing of your Personal Data will depend on the purpose of the processing. For most Personal Data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for our legitimate business interests. Where we process Personal Data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. If we are required to share Personal Data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device.
Depending on what Personal Data we collect from you and how we collect it, we may also rely on various grounds for processing your Personal Data, including the following reasons:
- Processing on the basis of legitimate business interests. When we process Personal Data on the basis that the processing is necessary for our legitimate business interests, such interests include: (i) providing, improving, and promoting our Services; (ii) communicating with current and potential customers, other business partners, and their individual points of contact; (iii) managing our relationships with our customers and other business partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information within the company, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our products, Services, and employees, including fraud protection.
- Processing on the basis of performance of a contract. Examples of situations in which we process Personal Data as necessary for performance of a contract include e-commerce transactions in which you purchase a service from us.
- Processing on the basis of consent. Examples of processing activities for which we may use consent as its legal basis include: (i) collecting and processing precise location information from your mobile device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing Personal Data on company Services through cookies and similar technologies when consent is required by applicable law.
- Processing because we are under a legal obligation to do so. Examples of situations in which we must processes Personal Data to comply with our legal obligations include: (i) providing your Personal Data to law enforcement agencies and other governmental bodies when required by applicable laws; (ii) retaining business records required to be retained by applicable laws; and (iii) complying with court orders or other legal process.
If the processing of your Information is based on your consent, the GDPR and Data Protection Act 2018 also allow users the right to access, revoke, or modify your consent at any time. Please see the How to Contact Us section, below, to review or modify your consents.
4. Consent to TransferWe are operated in the United States, and we may use service providers based in the United States to operate our business and our relationship with you. Please be aware that Information, including your Personal Data, that we collect will be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We maintain measures to address the transfer of your Personal Data between our group companies and between us and our third-party providers in accordance with applicable data protection laws and regulations.
5. Consent to TransferWe will retain your Information for as long as needed for the purposes described in this Privacy Policy. More specifically, the time we maintain your Information depends on the following factors:
- Whether we need the Information to provide the Services. We will maintain any data needed to provide you with the Services for as long as needed for us to provide you with the Services, respond to your questions and requests, and/or administer your account (if applicable).
- Whether we need the Information to comply with our legal obligations. We may have legal obligations to maintain your Information where a legal or regulatory body may ask for it in the future, for example in response to a data subject request or complaint. This information may include contact information and location information.
- Whether we need the Information for a legitimate business interest. We may store Information like contact information, cookies, and location information in order to perform analytics, troubleshoot errors, or improve our Services. In any event, we delete the Information when it is no longer needed for our legitimate interest.
Regardless of our reason for retaining your Information, we delete all Information in accordance with our routine record keeping policies.
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