“Personal Information” is information that is personally identifiable like names, addresses, e-mail addresses, or phone numbers, as well as other non-public information that is associated with the foregoing.
“Anonymous Information” means information that is not associated with or linked to your Personal Information; Anonymous Information does not permit the identification of individual persons.
YOUR PERSONAL INFORMATION MAY BE PROCESSED IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL AS OTHER COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY AND BY USING THE SERVICE OR SUBMITTING PERSONAL INFORMATION THROUGH THE SERVICES, YOU ARE EXPRESSLY CONSENTING TO SUCH PROCESSING.
As a general principle, your granting of any consent and your provision of any Personal Information hereunder is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide Personal Information. However, there are circumstances in which SupplyFrame cannot take action without certain Personal Information, for example because this Personal Information is required to process your orders or provide you with access to a web offering or newsletter. In these cases, it will unfortunately not be possible for SupplyFrame to provide you with what you request without the relevant Personal Information.
As part of a global group of companies, SupplyFrame has affiliates and third-party service providers within, as well as outside of, the European Economic Area (the “EEA”). As a consequence, whenever SupplyFrame is using or otherwise processing your Personal Information for the purposes set out in this Privacy Statement, SupplyFrame may transfer your Personal Information to countries outside of the EEA including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. Whenever such transfer occurs, it is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) in order to contractually provide that your Personal Information is subject to a level of data protection that applies within the EEA.
You can request from SupplyFrame at any time details about which Personal Information SupplyFrame processes about you and the correction or deletion of such Personal Information. Please note, however, that SupplyFrame can delete your Personal Information only if there is no statutory obligation or prevailing right of SupplyFrame to retain it. If you request that SupplyFrame delete your Personal Information, you will not be able to continue to use any SupplyFrame service that requires SupplyFrame’s use of your Personal Information.
If SupplyFrame uses your Personal Information based on your consent or to perform a contract with you, you may further request from SupplyFrame a copy of the Personal Information that you have provided to SupplyFrame. In this case, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like this information, and whether the Personal Information is to be sent to you or another recipient. SuppyFrame will carefully consider your request and discuss with you how we can best fulfill it.
Furthermore, you can request from SupplyFrame that we restrict your Personal Information from any further processing in any of the following events: (i) you state that the Personal Information SupplyFrame has about you is incorrect, (but only for as long as SupplyFrame requires to check the accuracy of the relevant Personal Information), (ii) there is no legal basis for SupplyFrame processing your Personal Information and you demand that SupplyFrame restricts your Personal Information from further processing, (iii) SupplyFrame no longer requires your Personal Information but you claim that you require SupplyFrame to retain such data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Information by SupplyFrame (based on SupplyFrame’s legitimate interest as further set out below) for as long as it is required to review as to whether SupplyFrame has a prevailing interest or legal obligation in processing your Personal Information.
Please direct any such request to firstname.lastname@example.org.
If you believe that SupplyFrame is not processing your Personal Information in accordance with the requirements set out herein or applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which SupplyFrame has its registered seat.
The data controller of www.supplyframe.com is Supply Frame, Inc., 61 S. Fair Oaks Avenue, Suite 200, Pasadena California, USA (“SupplyFrame”). SupplyFrame’s data protection officer is Michael Placido (email@example.com).
We collect the following Personal Information that you submit to us voluntarily:
Since the foregoing information may be collected when you are signed into the SupplyFrame Offerings or after you click on a link contained in an email sent by us, this information may be associated by us with Personal Information that we have collected from you.
SupplyFrame stores small text files called “Cookies” on your computer to make your experience on our website better. We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). In order to provide the SupplyFrame Offerings and other services, we use a variety of Cookies that perform different functions. We use the following types of cookies:
While you will still be able to use the SupplyFrame Offerings if you disable Cookies in your browser, certain parts of the SupplyFrame Offerings may not function as effectively. You can find more information on Cookies and how they may affect you by visiting: www.youronlinechoices.com.
We may receive Personal Information about you from outside the Sites, such as from third parties that provide services for us that are related to the SupplyFrame Offerings. We may add this information to the information we have already collected from you via the SupplyFrame Offerings.
In general, information (including Personal Information) you submit to us, or to third parties that support us in collecting information, is used by us to provide you and others with the SupplyFrame Offerings, to respond to requests that you make, to improve our SupplyFrame Offerings, and to better tailor the features, performance and support of the SupplyFrame Offerings.
We may also use your Personal Information to provide you with notifications related to your use of the SupplyFrame Offerings, such as electronic newsletters or promotional e-mails.
We may create Anonymous Information records from Personal Information by excluding information (such as your name) that makes the information personally identifiable to you. We may also create Anonymous Information on how you use the SupplyFrame Offerings. We may use this Anonymous Information for internal purposes, such as analyzing usage patterns so that we may enhance the SupplyFrame Offerings, and we also reserve the right to use and disclose any Anonymous Information at our discretion.
In the following cases, SupplyFrame is permitted to process your Personal Information under the applicable data protection law.
If you participate in tutorials or trainings provided by SupplyFrame, we may also track your learning progress in order to make this information available to you. Furthermore, we communicate on a regular basis by email with users who subscribe to our services, and we may also communicate by phone to resolve customer complaints or investigate suspicious transactions. We may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. emails and phone calls), SupplyFrame will (i) where legally required only provide you with such information after you have opted in and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us.
SupplyFrame and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, SupplyFrame is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through SupplyFrame Sites or other delivery channels controlled by SupplyFrame. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to SupplyFrame’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match.
Furthermore, you acknowledge that any information required to track your choices regarding the processing or use of your Personal Information or receipt of marketing materials (that is to say, depending on the country in which the relevant SupplyFrame company operates, whether you have expressly consented to or opted out of receiving marketing materials) may be stored and exchanged between members of SupplyFrame as required to ensure compliance.
In the following cases SupplyFrame will only use your Personal Information as further detailed below after you have granted your prior consent into the relevant processing operations.
SupplyFrame may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own data bases in order to display to you more relevant information.
SupplyFrame offers you the option to use its Offerings including forums, blogs, and networks linked to its Sites that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.
These profiles may relate to a single Offering of SupplyFrame or may also allow you to access other Offerings of SupplyFrame or of other entities of SupplyFrame, or both (irrespective of any consent granted under the section “Forwarding Your Personal Data To Other SupplyFrame Companies.” below). It is, however, always your choice which of these additional Offerings you use and your Personal Information is only forwarded to them once you initially access them. Kindly note that without your consent for SupplyFrame to create such user profiles, SupplyFrame will not be in a position to offer such services to you where your consent is a statutory requirement that SupplyFrame can provide these services to you.
Within any Offerings, beyond the mere provision of access, your profile is used to personalize interaction with other users (for example, by way of messaging or follow functionality) and by SupplyFrame to foster the quality of communication and collaboration through such Offerings and for SupplyFrame to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant Offerings, you can use the functionality of the relevant Offerings to determine which information you want to share.
Special categories of Personal Information. In connection with the registration for and provision of access to an event or seminar, SupplyFrame may ask for information about your health for the purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout the event. Any such use of information is based on the consent you grant hereunder.
Kindly note that if you do not provide any such information about disabilities or special dietary requirements, SupplyFrame will not be able to take any respective precautions.
If you register for an event, seminar, or webinar of SupplyFrame, SupplyFrame may share basic participant information (your name, company, and email address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.
SupplyFrame may transfer your Personal Information to other entities owned by SupplyFrame. In such cases, these entities will then use the Personal Information for the same purposes and under the same conditions as outlined in this section.
You may at any time withdraw a consent granted. In case of withdrawal, SupplyFrame will not process Personal Information subject to this consent any longer unless legally required to do so. In case SupplyFrame is required to retain your Personal Information for legal reasons your Personal Information will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of Personal Information by SupplyFrame up to the point in time of your withdrawal. Furthermore, if your use of an SupplyFrame Offering requires your prior consent, SupplyFrame will not be (any longer) able to provide the relevant service, offer or event to you after your revocation.
Where SupplyFrame is subject to U.S. privacy requirements, the following also applies:
Do Not Track. Your browser may allow you to set a “Do not track” preference. Unless otherwise stated, our Sites do not honor “Do not track” requests. However, you may elect not to accept Cookies by changing the designated settings on your web browser. Please note that if you do not accept cookies, you may not be able to use certain functions and features of our site.
Please note that we may disclose certain of your Personal Information, such as your username, to other Users of certain SupplyFrame Offerings in order to identify you as a User of the SupplyFrame Offerings. In addition, certain information that you have provided on an optional basis in connection with registering with our SupplyFrame Offerings (your gender, birthday, phone number, address, city, state, country, and website) may be made available on your profile to other Users of all the SupplyFrame Offerings; please make sure that you only provide the information that you feel comfortable sharing with others in this way.
We may enter into agreements with companies that provide the SupplyFrame Offerings by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (“Third Party Companies”). A Third Party Company may want access to Personal Information that we collect from its customers. As a result, we may disclose your Personal Information to a Third Party Company; however, we will not disclose your Personal Information to Third Party Companies for the Third Party Companies’ own direct marketing purposes, unless you have “opted-in” by following the instructions we provide to allow such disclosure. If you have opted-in to receive e-mail communications from a Third Party Company and later wish to discontinue receipt of these e-mails, please contact the Third Party Company directly to update your preferences. The privacy policies of our Third Party Companies may apply to the use and disclosure of your Personal Information that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of our Third Party Companies, you should read and understand their privacy policies.
We may provide your Personal Information to third party service providers and suppliers who work on behalf of or with us to provide you with some of the services and features of the SupplyFrame Offerings and to help us communicate with our users (including in connection with payments). However, these service providers and suppliers do not have any independent right to use this information except to help us provide the SuplyFrame Offerings.
We will include unsubscribe instructions in each newsletter or promotional communication you receive from us.
You may change any of your Personal Information in your Account by editing your profile within the SupplyFrame Offerings. You may request deletion of your Personal Information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete Personal Information that we have collected from or about you, it will be deleted from our active databases but may remain in our archives.
We do not intend for our Sites or online services to be used by anyone under the age of 13. If you are a parent or guardian and believe we may have collected information about a child, please contact us at firstname.lastname@example.org.
SupplyFrame is committed to safeguarding and securing the information we collect online. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. However, no company, including SupplyFrame, can fully eliminate security risks associated with Personal Information.