Effective [DATE], 2019
This Privacy Notice (the “Privacy Notice”) describes how [Ashland Office Supply, Inc.] collects, uses, and shares your personal data.
This Privacy Notice applies to your use of [Ashland Office Supply, Inc.]’s website home page (also called “a landing page”) (collectively, the “Services”) and describes our privacy practices relating to the Services. This Privacy Notice does not apply to other parts and sections of the [Ashland Office Supply, Inc.]’s websites, including the e-commerce section located at http://shop.[ashlandoffice.com that permits visitors to purchase item listed on the home page. It does not apply to [Ashland Office Supply, Inc.] mobile applications, and all other digital and online services provided by [Ashland Office Supply, Inc.], if any. Lastly, this Privacy Notice does not apply to information collected by [Ashland Office Supply, Inc.] offline, or to third party websites, applications, or services (including any other affiliates’ or organizations not named above).
1. Contact Information
Ashland Office Supply, Inc.
[2100 29th Street Ashland, KY 41101]
If you have any comments or questions about how we collect and use your personal data, communication can be directed to our postal address, via email to [email] or by telephone to [phone].
2. Applicability & Eligibility
We need to process your personal data to operate our organization and provide you with the Services as defined above.
By accepting our Privacy Notice, you are confirming that you have read and understood these policies, including how and why we use your information. If you don’t want us to collect or process your personal data in the ways described in this Privacy Notice, you should not use the Services. Please note we are not responsible for the content or the privacy policies or practices of any third party organization or service.
The Services are not directed to children under the age of 18. You may not use the Services if you are under the age of 18. If you are under the age of 18, you should not provide any information on our Services.
3. Information Collection, Use & Sharing
[Ashland Office Supply, Inc.] collects information about you and your use of the Services through various means, including when you provide information to us and when we automatically collect information about you when you access, use, or interact with the Services. Such processing is performed to provide you with the Services. In some instances, you may be able to choose what information to provide, but sometimes we require certain information for you to use and for us to provide you the Services.
Where we process your information on the basis of consent, we will clearly obtain your opt-in consent. Where given, you may withdraw your consent at any time by contacting us at [email protected][ashlandoffice.].com. Where we process your information on the basis of legitimate interests, we do so where the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.
The types of information [Ashland Office Supply, Inc.] may collect about you include:
3.1 Information You Provide To Us:
We generally process the information you provide to us on the legal basis of [Ashland Office Supply, Inc.]’s legitimate interests in performing the function or service you requested. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.
Correspondence Information: If you sign up for our mailing list or email us, we may keep your message, email address, and contact information to respond to your requests, provide the requested products or Services, and to provide notifications or other correspondences to you.
If you do not want to receive communications from us in the future, please let us know by sending us an e-mail requesting the same to privacy ashlandoffice.].com or by following the unsubscribe instructions found in any e-mail we send. If you supply us with your postal address, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by contacting us at [email protected][ ashlandoffice.].com or by calling our phone number provided above.
Please note requests to remove your email address from our lists may take some time to fulfil. We may also still contact you as needed to provide important announcements or notifications regarding the Services.
Support Information: You may provide information to us via a support request submitted through the Services. We will use this information to assist you with your support request and may maintain this information to assist you or other users with support requests. Alternatively, please contact us via phone at [Ashland Office Supply, Inc.’s phone number] to request our support.
Form Information: We may use forms to request certain information from you on the Services, such as your contact information to assist with contacts or service requests. This information may include personal data.
3.2 Information We Collect Automatically:
We may use automatic data collection and analytics technologies to collect aggregate and user-specific information about your equipment, domain name, patterns of use, communication data and the resources that you access and use on the Services, including your IP address, browsing, and navigation patterns. This information is used to improve our Services.
We generally process information collected automatically on the legal basis of [Ashland Office Supply, Inc.]’s legitimate interests in assessing the use of its Services. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.
Information we collect automatically through your use of the Services includes:
IP Addresses: Our Service Providers automatically collect the IP addresses of our visitors users.
Unique Identifiers: When you use or access the Services, our Service Providers may also access, collect, monitor, store on your device, and/or remotely store one or more “Unique Identifiers,” such as a universally unique identifier (“UUID”).
Analytics Information: We use data analytics to ensure site functionality and improve the Services. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.
Log File Information: When you use our Services, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with our Services, for example, when you visit our website, sign in to our Services, or interact with our email notifications. [Ashland Office Supply, Inc.] uses log file data to provide, understand, and improve our Services, and to customize the content we show you. [Ashland Office Supply, Inc.] may link this log file to other information [Ashland Office Supply, Inc.] collects about you via the Services.
3.3 Information Use
[Ashland Office Supply, Inc.] uses the information we receive about you for the purposes described in this Privacy Notice. We generally process personal data received about you through our Services on the legal basis of [Ashland Office Supply, Inc.]’s legitimate interests in providing the Services and their functionality to you where such processing is necessary for the purposes of the legitimate interests pursued by [Ashland Office Supply, Inc.] or by our Service Providers related to the Services. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.
[Ashland Office Supply, Inc.] will generally use your information in the following circumstances on the legal basis of legitimate interests to provide the Services requested:
Providing and Improving Our Services: We may use your information to improve and customize our Services, including sharing of your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users and obtaining insights into usage patterns of our Services.
Keeping Our Services Safe And Secure: We may also use your information for safety and security purposes, including sharing of your information for such purposes, and we do so because it is necessary to pursue our legitimate interests in ensuring the security of our Services, including enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kind.
Advertisements: [Ashland Office Supply, Inc.] may serve ads and banners to you when you use our Services. These ads and banners, however, do not collect personal information about you. We merely measure the effectiveness of these ads and banners; specifically, whether you have clicked on the banner. The information collected may allow us to track what ads and banners are used by and are of interest to visitors so that we may provide better, more targeted advertising regarding our business and Services.
3.4 Information Sharing
When you access or use the Services, we collect, use, share, and otherwise process your personal data as described in this Privacy Notice. [Ashland Office Supply, Inc.] will not share, sell, rent, or otherwise disclose your private personal data to third parties without your consent or another valid legal basis permitted by law.
[Ashland Office Supply, Inc.] will share your information in the following circumstances on the legal basis of the legitimate interests of providing the requested Services:
Within [Ashland Office Supply, Inc.]: We may share and process information internally within [Ashland Office Supply, Inc.] and with our subsidiaries and affiliates. [Ashland Office Supply, Inc.]’s personnel may have access to your information as needed to provide and operate the Services in the normal course of business. This includes information regarding your use and interaction with the Services.
Service Providers: [Ashland Office Supply, Inc.] work with various organizations and individuals to help provide the Services to you (“Service Providers”), such as website and data hosting companies and companies providing analytics information, like Google Analytics, or companies that permit us to communicate with our customers or potential customers via email, including ConstantContact and Aviso. [Ashland Office Supply, Inc.] needs to engage such third-party Service Providers to help us operate, provide, and market the Services. These third parties have only limited access to your information and may use your information only to perform these tasks on our behalf. Information we share to our Service Providers may include both information you provide to us and information we collect about you, including personal data and information from data collection tools like cookies, web beacons, and log files.
If [Ashland Office Supply, Inc.] becomes aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.
We share personal data with our Service Providers on the legal basis of [Ashland Office Supply, Inc.]’s legitimate interests in providing you with the Services. Our engagement of Service Providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Services operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.
Business Transactions: [Ashland Office Supply, Inc.] may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Your information, including personal data, may be among assets sold or transferred as part of a Business Transaction. In some cases, [Ashland Office Supply, Inc.] may choose to buy or sell assets. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enables our organization to develop over the long term.
Safety and Lawful Requests: We may be required to disclose Services user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Services or using [Ashland Office Supply, Inc.] name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Notice is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
Aggregated Non-Personal Data: We may disclose aggregated, non-personal data received from providing the Services, including information that does not identify any individual, without restriction. [Ashland Office Supply, Inc.] may share demographic information with business partners, but it will be aggregated and de-personalized so that personal data is not revealed.
4. Choices Regarding Your Information
4.1 Data Retention
[Ashland Office Supply, Inc.] will retain your information for as long as is necessary for the purposes set out and decribed in this Privacy Notice, or as needed to provide the Services to you. [Ashland Office Supply, Inc.] will also retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this Privacy Notice.
4.2 Opting-Out Of Communications From [Ashland Office Supply, Inc.]
Users may opt-out of receiving certain communications from [Ashland Office Supply, Inc.] by following the unsubscribe process described in email communication, or by contacting us using the contact information provided above. However, please note you may not opt-out of certain Services-related communications, such as account verification, changes or updates to features of the Services, or technical and security notices.
4.3 Do Not Track
[Ashland Office Supply, Inc.] does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use Services. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.
5. Information Security
The security of your personal data is important to us. [Ashland Office Supply, Inc.] takes reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration, and destruction. [Ashland Office Supply, Inc.] implements security measures as we deem appropriate and consistent with industry standards. As no data security protocol is impenetrable, [Ashland Office Supply, Inc.] cannot guarantee the security of our systems or databases, nor can we guarantee that personal data we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from Services is provided at your own risk.
6. Additional Provisions Regarding The Services & Your Information
6.1 Processing Necessary For The Performance Of The Contract
You can choose whether or not you want to use the Services. We cannot provide many of the Services without your agreement to this contract, and without moving your personal data to [Ashland Office Supply, Inc.] entities and Service Providers in various jurisdictions. Therefore certain processing of your personal data is done on the legal basis of processing necessary for the performance of the contract between you, as a user of the Services, and [Ashland Office Supply, Inc.].
6.2 Safely Using [Ashland Office Supply, Inc.]’s Services
Despite [Ashland Office Supply, Inc.]’s safety and privacy controls, we cannot guarantee the Services are entirely free of illegal, offensive, or otherwise inappropriate material, or that you will not encounter inappropriate or illegal conduct from other users when using the Services. You can help [Ashland Office Supply, Inc.] by notifying us of any unwelcome contact by contacting us using the information below.
6.3 Your California Privacy Rights
Under California Civil Code Section 1798.83 (known as the ”Shine the Light“ law), [Ashland Office Supply, Inc.] Services users and customers who are residents of California may request certain information about our disclosure of personal data during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at [email protected][Ashland Office Supply, Inc.].com with “Request for California Privacy Information” on 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.
7. Changes to Our Privacy Notice
[Ashland Office Supply, Inc.] may modify this Privacy Notice from time to time. The most current version of this Privacy Notice will govern our use of your information and will be located at [Ashland Office Supply, Inc.]’s website home page. You may contact us to obtain prior versions. We will notify you of material changes to this policy by posting a notice at the Services or by emailing you and provide an “at a glance” overview of any changes.