Ambry Hill Technologies Global Privacy Policy

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INTRODUCTION AND DEFINITIONS

We encourage you to read this Global Privacy Policy. Customers may refer to their Master Services Agreement for other information not found here or contact support@ambryhill.com.

This Global Privacy Policy explains data privacy practices, defines users’ (“you” or “your”) privacy options, and describes how information is collected and used by Ambry Hill Technologies (“we,” “us,” “our,” or “AHT”) and describes options relating to the collection and use of personal information.

By using the AHT website or any of our applications, products, services, features, tools, or resources, you agree to the terms of this Global Privacy Policy and you consent to the collection and use of the information as described herein.

This Global Privacy Policy, along with our Master Services Agreement (“MSA”) which is provided to our subscribing customers, governs the use of the AHT websites (“Sites”), applications, products, services, features, tools, or resources, sub-processors, and any information we may access through email or social media platforms such as Facebook, Instagram, LinkedIn or Twitter.

In the event there is uncertainty between the Global Privacy Policy and the Master Services Agreement, the MSA takes precedent for subscribing customers. For the purposes of this Global Privacy Policy, we will refer to all these access points as the AHT system (“System”).

GLOBAL PRIVACY FUNDAMENTALS

Our privacy practices reflect current global principles and standards on handling personal information. These principles include notice of data use, choice of data use, data access, data integrity, security, onward transfer, and enforcement/oversight. We abide by the privacy laws in the countries where we do business.

REVISIONS TO THE GLOBAL PRIVACY POLICY

We may update this policy from time to time and will mark new versions with the new effective date. If we decide to make changes to this privacy statement, we will post the changes on this site so that you will always know what information we collect, and how we use it. We recommend you visit the Site to review any changes in our practices. Your continued use of the System constitutes your agreement to our then-current Global Privacy Policy.

WHAT INFORMATION IS COLLECTED?

Information Collected Automatically

We use tracking technologies such as cookies, log files, and pixel tags to automatically collect information when users visit our System. We collect:

  • - IP addresses to measure our website traffic and to help provide a more personalized experience;
  • - Information regarding your browser and other technical specifications required to use our System;
  • - Your transaction history relating to the use of our products and services;
  • - Computer data or files often called “cookies,” which may be sent by your web browser and stored on an individual computer to allow our server to “recognize” you through the navigation of our Sites; and
  • - Computer data files often called “web beacons” that are collected from emails or links on third-party sites that allow our server to evaluate the popularity of those links or the information contained in emails or on third-party sites.
  • - This Global Privacy Policy does not pertain to transactional data in the Vista product lines. Subscribing customers may refer to their MSA for details regarding transactional data.

For more information, see the “Cookies and Similar Technologies” section below.

We collect personal information about you when you sign up for a mailing list, register an account, fill out a “Contact Us” form, submit information in connection with a purchase or as part of other online services.

The information collected may include, but may not be limited to your name, email address, phone number, physical address, other contact information, financial information necessary to process a purchase or other request, business affiliations, and other information related to your requests or inquiries.

Collecting Information from Children Under the Age of 16

Our Sites and System are not designed for children, and we do not knowingly collect information from any person under the age of 16.

HOW IS THE INFORMATION WE COLLECT USED?

We collect information about you to provide you with services and products, and to collect information that is necessary for the System to work properly. We use personal information for a variety of purposes related to our business:

Providing services and support

Performing the essential functions of the System including responding to inquiries, fulfilling orders and requests, processing payments, providing support and troubleshooting, and communicating with users about their use of the System or regarding a user-initiated inquiry on the System.

We communicate with users who subscribe to our services on a regular basis via email, online chat, and we may also communicate by phone to resolve customer complaints or investigate suspicious activities. 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 primarily informational in nature rather than promotional.

Communicating with users about products or services

Sending or initiating direct marketing programs, such as newsletters or information about new products or services we are offering; using content from social media platforms where users discuss our products or use a hashtag related to our products.

Personalizing user experiences on our System

Tailoring content on the System based on user location, preferences, and other personalization factors.

Analytics and System improvement

Tracking information about your visits to our Sites or use of the System to allow us to provide better service, using certain online preferences in the aggregate across all users to evaluate the System and develop additional products and services to offer.

Compliance with legal obligations

Sharing information to comply with the law or a legal proceeding, such as in response to a subpoena or court order.

Other

Other purposes necessary to carry out our obligations under this Global Privacy Policy or our Master Service Agreements.

DISCLOSURE OF INFORMATION

We may share information, in the aggregate, regarding your online browsing preferences to evaluate our products or allow the third parties we work with to better serve our users. We will not share personally identifiable information in these instances, other than as described in this Global Privacy Policy.

We will not share your information with third parties to directly market their products to you. We may provide user information to third-party service providers, sub-processors, or vendors for the following purposes, including but not limited to:

  • - Initiating direct marketing programs on our behalf,
  • - Data tracking,
  • - Maintenance or development of our System,
  • - Development of online products, services, or customer service, or new product development,
  • - Other contracted promotional opportunities are provided to our users.

We may also share this information with any parent companies, or other related entities and their respective owners for the purposes of routine business activities. We may also share your personal information in connection with law enforcement requests or in response to investigations, subpoenas,court orders, or other legal processes to establish or exercise our legal rights or defend against legal claims, or as otherwise required by law.

Business Transfers

We may also disclose your information to a third party as part of reorganization or a sale of the assets of AHT, or its subsidiaries or divisions. Any third party to which AHT transfers or sells the System or related assets will have the right to continue to use the personal and other information that you provide to us.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies, pixel tags, and similar technologies to gather information about your use of our System and to customize your experience using the System.

Cookies

Cookies are small data files that help us keep track of your usage of the System. Many of the cookies we use enable the System to function as you would expect it to. Cookies enable the System to remember things like your login information, so you do not have to re-enter it, user preferences, and other personalized settings. Cookies also enable us to track and analyze user behavior to improve our System. Most web browsers automatically accept cookies, but you can choose to accept or decline certain types of cookies if you prefer. However, declining cookies may impact the functionality of the System and in some cases, you may not be able to access the functions of the System. We use the following categories of cookies on the System:

Session cookies

Session cookies are stored on the user’s hard drive temporarily and is deleted when the user ends the browsing session. Session cookies are useful for things like keeping user preferences while the user continues to browse.

Persistent cookies

Persistent cookies stay on the user’s hard drive until they expire, even after the browser is closed. Persistent cookies are useful for remembering things like login information, so users do not have to enter their password every time they visit the System; or to retain a user’s System customizations such grid view customizations.

Third-party cookies

Third-party cookies are not installed directly by our System, but by third parties such as advertisers. Third-party cookies are used to track advertising preferences from site to site and to gather data about user's browsing habits to improve the user experience.

Clear GIFs

Clear GIFs (also called pixel tags or web beacons) are small files embedded in websites that tell us what content a user accesses and how users navigate the System. Clear GIFs enable us to track and analyze user behavior on the System to make it more intuitive and user-friendly.

THIRD-PARTY WEBSITES, SUB-PROCESSORS, AND LINKS

Our System may contain links to other websites. These websites may have privacy policies different from our Global Privacy Policy. The System may also contain certain social media icons or widgets. Although you can view the material we have linked to, you may have to create an individual account or register to use these third-party social media sites to use interactive features. Any interaction on social media or other third-party websites is governed not by this Global Privacy Policy but by the terms of use and Privacy Policy of that particular platform.

Embedded Web Links

Emails from AHT often use links designed to lead you to a relevant area on the web after redirection through AHT servers. The redirection system allows AHT to change the destination URL of these links, if necessary, and to determine the effectiveness of our marketing initiatives.

In emails, such links may also allow AHT to determine if you have clicked on a link in the email, and the information about this interaction may be connected to your personal identity. If you do not want AHT to collect information about the links you clicked, you can simply choose not to click on the links in an e-mail that AHT sends you or unsubscribe.

Sub-Processors

You consent to Ambry Hill’s use of sub-processors to provide aspects of the System services, and to Ambry Hill’s disclosure and provision of your personal data to those sub-processors. Ambry Hill shall be responsible for the performance of its sub-processors. Ambry Hill shall ensure sub-processors are subject to contractual obligations which are the same as or equivalent to those imposed on Ambry Hill regarding processing of personal data.

DATA PROTECTION

We maintain administrative, physical, and technical safeguards for all user information collected in our System. We are committed to protecting the personal data you share with us. AHT uses a combination of industry-standard security audits, assessments, technologies, procedures, and organizational measures to help protect your personal data from unauthorized access, use or disclosure. AHT supports online security using secure server technology and other security arrangements and facilities to prevent abuse. We bind our employees to observe your privacy and confidentiality rights.

Regulatory and Compliance

In respect of personal data provided to Ambry Hill by you, Ambry Hill shall comply, and shall ensure that its personnel comply, with the requirements of state, federal and national privacy laws and regulations governing such personal data in Ambry Hill’s possession or under its control and applicable to Ambry Hill’s provision of System services. You are solely responsible for ensuring you, and your users, compliance with any legal, regulatory or similar restrictions applicable to the types of data you elect to process with the System.

Data Security

Ambry Hill shall implement and maintain commercially reasonable technical and organizational security measures designed to meet the following objectives: (i) ensure the security and confidentiality of your data in the custody of and processed by Ambry Hill; (ii) protect against any anticipated threats or hazards to the security or integrity of such data; (iii) protect against unauthorized access to or use of such data; and (iv) ensure that Ambry Hill’s return or disposal of such data is performed in a manner consistent with Ambry Hill’s obligations under items (i)-(iii).

More about data protection is provided to customers in their Master Services Agreement, Section 7.

DATA RETENTION

We retain data collected from you only for as long as necessary to complete the purpose for which it was collected. In all cases, data will be retained for no longer than 5 years after your subscription is terminated by either party unless otherwise required to fulfill our legal obligations.

INTERNATIONAL DATA PROCESSING

AHT is located in the United States and all data related to the System (as defined below) is collected and processed by AHT in the U.S. If you are not located in the U.S., your personal data will therefore be transferred to, processed, and stored in a country outside of the country where you live. By submitting your personal information to us, you are consenting to the processing of your personal information in the U.S.

For European Union data subjects, your personal data may be transferred outside the European Union to the U.S. to provide you with goods, services, and information you request, with your consent, or in accordance with a legitimate interest of AHT. All personal data will be processed for lawful purposes as described in this Global Privacy Policy, including necessary for the performance of the contract between you and AHT, necessary to comply with legal requirements, with your consent, or necessary for the legitimate interests of AHT. Further, if you are a European Data subject and we are processing your personal data on the basis of your consent, you may revoke your consent at any time by emailing us at support@ambryhill.com. Such withdrawal does not affect the lawfulness of the processing prior to the withdrawal of consent. Further, withdrawal of consent does not affect the processing of information based on other lawful bases of processing other than consent.

With respect to personal data that is transferred from the European Economic Area to the United States, Ambry Hill represents that Ambry Hill is certified under the EU-U.S. Data Privacy Framework (EU-U.S. DPF) program, which is administered by the International Trade Administration (ITA) within the U.S. Department of Commerce (https://www.dataprivacyframework.gov/) and warrants that it shall maintain such certification and abide by its principles during the currency of the program or the agreement term, whichever is shorter.

ACCESS AND CORRECTION RIGHTS

European Union data subjects may file a complaint with a data protection authority regarding our processing of your personal data. For more information, please contact your local data protection authority. Contact information of European supervisory authorities is available here:http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Data Subject Rights

European Union data subjects have certain rights under the GDPR, including the following:

Right of Access

You may have the right to access data collected about you. If you would like to know exactly what information we have collected about you and how it has been used, please contact us.

Right of Rectification

You may have a right to correct any incorrect or incomplete information we have about you. To request a correction, please contact us.

Right to Erasure

In certain circumstances, you may have the right to request that we delete your personal information.

Right to Restrict Processing

In certain circumstances, you may have the right to restrict the processing of your personal information. To exercise your right to restrict processing please contact us. You may have the right to restrict the processing of your information if:

  • - You have objected to the accuracy of your information, and we are in the process of verifying or correcting it;
  • - We have processed your data unlawfully and you would prefer that the information be restricted rather than erased; or
  • - You object to us processing your data and we are in the process of determining whether there are any overriding business interests.

Right to Object

You may have the right to object to the processing of your personal data for direct marketing purposes. AHT provides you the opportunity to exercise an opt-out choice if you do not want to receive other types of communication from us such as emails or updates regarding new services and products or if you do not want us to share your personal information with third parties as detailed herein. To object to the processing of your personal data please contact us.

Rights Related to Automated Decision-Making Including Profiling

You have the right not to be subject to a decision based solely on an automated process (no human involvement) that produces legal effects or significantly affects you in a similar way. We will not make these types of decisions by solely automated processed. If you believe that an automated decision-making process was applied to you, please contact us.

Your Other Options

While we work hard to use and disclose our users’ personal information only for the purposes identified above, you can choose not to provide personal information or limit the personal information obtained by us as follows:

  • - You may have your contact information removed from our marketing lists to inform users of new or relevant products, services, and special offers by clicking on the unsubscribe link in any communication received from us, or by emailing us at sales@ambryhill.com;
  • - You may limit the collection of “cookies” through your browser settings. However, this may disable our ability to provide you with the most relevant products or information regarding the System; and
  • - You may limit the ability of Google Analytics to track your online activity, as outlined in the “Do Not Track Signals” section.
YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code § 1798.83 permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us.

DO NOT TRACK SIGNALS

The System does respond to Do Not Track signals. If a user has the Do Not Track option enabled, the System will not track and analyze your behavior on the System. However, third parties affiliated with the System through advertising and other relationships may not respond to Do Not Track signals. We are not responsible for third-party affiliates’ responses to Do Not Track signals. Users should check third-party privacy policies to determine how they respond to Do Not Track Signals.

DISPUTE RESOLUTION AND ENFORCEMENT

Any notice or report required or permitted to be given or made under the Global Privacy Policy by either party shall be in English, in writing and be deemed to have been fully given and received (i) when delivered personally; (ii) when sent by confirmed facsimile; (iii) five (5) days after having been sent by registered or certified mail, return receipt requested, postage prepaid; (iv) one (1) day after deposit with a commercial overnight carrier, with written verification of such receipt; or (v) to the extent expressly permitted in the Global Privacy Policy, one (1) day after being sent via email. Notices shall be sent to the parties at the addresses specified in writing to the other. All notices to Ambry Hill must be made to the address(es) listed below and all notices sent to a complainant must be made to the mailing or email address of complainant’s primary contact with Ambry Hill.

In compliance with the EU-U.S. DPF, we commit to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) regarding unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF. Under certain circumstances, European Union subjects may invoke binding arbitration for complaints regarding our DPF compliance not resolved by any of the other DPF mechanisms described herein. For additional information, please visit https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2

The Federal Trade Commission has jurisdiction over AHT’s compliance with the Data Privacy Framework program.

For additional information, answers to questions, concerns, access requests, or any other notice pertaining to our Global Privacy Policy or DPF program, please contact:

Ambry Hill notice address:
ATTN: General Counsel
134 Adams Street South Cambridge, MN. 55008
legal@ambryhill.com

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