UPDATED JULY 10, 2020
Asher Del Buono and Sarah Del Buono DBA “Caulfield Cables” and all of its affiliates and subsidiaries ("Caulfield Cables" or "us" or "we" or "Company") appreciate your use of and contributions to our websites, our mobile and desktop applications, our other properties or our related services (collectively known as the "Caulfield Cables Properties" or, each individually, a "Caulfield Cables Property") and we understand your concerns about privacy. So, we want you to understand what types of information we collect on this site and what may happen to that information.
Attn: Legal Department
2. INFORMATION WE COLLECT
A. Personally Identifiable Information or Personal Information or Personal Data
You are not required to provide Personally Identifiable Information, defined as information relating to an identifiable natural person, in order to visit Caulfield Cables Properties. You must, however, register and provide Personally Identifiable Information in order to access certain portions or use some or all of the features of certain Caulfield Cables Properties, receive Caulfield Cables communications, and to enter contests and other promotions.
Caulfield Cables may use content you provide us through emails, responses to polls, contests or sweepstakes or any other promotional activity. Please be advised that your submissions become the property of Caulfield Cables and may be used by Caulfield Cables for any lawful purpose, subject to applicable law. Caulfield Cables can edit, rewrite, use, and reuse the content of your submissions, including your name, likeness, photograph, and biographical information in any way and in any media whether now known or invented in the future, with or without attribution, including publication in online publications, trade media, and advertising. You agree that any content you send us will not violate any rights of any third-party and that you will only send us content for which you own the rights.
- IP Addresses. Your Internet Protocol ("IP") address is usually associated with the place from which you enter the Internet, like your Internet Service Provider, your company or your university. By collecting your IP address, Caulfield Cables' server may record the referring page that linked you to the Caulfield Cables website (e.g., another website or a search engine), the pages you visit on this website, the website you visit after this website, the ads you see or click on, other information about the type of web browser, computer, platform, related software and settings you are using, any search terms you have entered on this website or a referral website, and other web usage activity and data logged by our web servers. Caulfield Cables may also use your IP address to help diagnose problems with our servers, gather broad demographic and geographic information, and administer our website. Caulfield Cables may also link this information with your Personally Identifiable Information when Caulfield Cables feels that it is necessary to enforce compliance with its rules and policies, terms of service, or to protect its website, customers or others.
- Web Beacons. Web beacons are Internet tools, such as transparent images on a website or in e-mails that we may send you that help us to determine, for instance, whether a page has been viewed or an e-mail opened. For example, when you ask us to send you information on a promotion or newsletter, we may use web beacons to determine how many of the e-mails we sent were actually opened. In general, any electronic image viewed as part of a web page, including a banner ad, can contain a web beacon.
We participate in behavior-based advertising. This means that a third party may use technology such as cookies to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our websites, or on other websites. You can opt-out of receiving advertising based upon your browsing behavior from some network advertising companies by going to the Network Advertising Initiative and the Digital Advertising Alliance websites, although to completely prevent advertising based upon your browsing behavior you should also disable the cookies on your browser. One of the third parties that may track you on our websites is Google AdWords Remarketing; this is used to advertise Caulfield Cables products across the Internet. If you do not wish to participate in our AdWords Remarketing, you can opt out by visiting Google's Ads Preferences Manager.
Caulfield Cables has a legitimate interest in the collection of this personal information for the purposes of providing account related functionalities, making our website operate efficiently, participating in behavior based advertising, understanding our users and providing tailored services, understanding how users interact with our communications to you, providing efficient staffing and workforce operations, sharing information about our products and services, fulfilling our partner promotions, understanding consumer opinions, and operating sweepstakes.3. HOW WE USE YOUR INFORMATION
Caulfield Cables uses Personal Information you share with us either:
- based on your consent; or
- insofar as such processing is necessary for the performance of a contract between you and Caulfield Cables.
Sale and Customer Service: Caulfield Cables uses your information to fulfill your order and provide you with customer service.
Direct Marketing: Caulfield Cables uses your contact information for its own marketing purposes, e.g. to update you on our latest products, promotional offers and events.
If you are an existing customer and have provided your email to Caulfield Cables in the course of a commercial transaction; when you register for an account or interact with our website and services; when you communicate with us or sign up for promotional materials; when you participate in special activities, offers, or programs; when you engage with our online communities or advertising; or when you connect with us through social media with Caulfield Cables, we may use your email or social media contact information to contact you about Caulfield Cables goods and services, promotional offers and events. If you do not wish to be contacted for such marketing purposes and wish to opt out, please contact us.
Caulfield Cables does not sell, rent or loan any of your Personally Identifiable Information to any third party.
Caulfield Cables may, however, use and share information with third-party data processors specifically engaged by Caulfield Cables in the processing of your information received via the Caulfield Cables website. Caulfield Cables may also share your information with our foreign and domestic affiliates and subsidiaries and third-party suppliers, which may require sending your Personal Information to another country outside of the EU, where national laws may provide for a data protection level that is not equivalent to EU standards.
Website Administration: Caulfield Cables will use your information to administer its site and maintain your account (including troubleshooting, data analysis, testing, site improvement, website security).
Caulfield Cables will use your Personally Identifiable Information only for the purpose of communicating to and with you as requested or any other purpose for which you disclose it specifically to us. If you wish for us to cease use of your Personally Identifiable Information in any way, you may contact us at any time as set forth below.
Without your consent Caulfield Cables will use any Personal Information you provide only insofar as such processing is permitted by applicable law, e.g. for the performance of a sales contract with you or where such processing is necessary for compliance with a legal obligation to which Caulfield Cables is subject.
In addition, Caulfield Cables may use and share aggregated anonymous information that does not uniquely identify you when it enables Caulfield Cables to improve and enrich our services and website content.
Caulfield Cables reserves the right to use and share your information where such disclosure may be required by law.
4. RECIPIENTS OF PERSONAL INFORMATION
Caulfield Cables may share information with third parties in the following situations:
- Legal Process. Caulfield Cables may share your Personally Identifiable Information with third parties in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws.
- Legal Claims. Caulfield Cables may share your Personally Identifiable Information with third parties in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
- Other situations. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
This website is not intended for use by children age under age 16. No one under age 16 is allowed to provide any Personally Identifiable Information or use Caulfield Cables public discussion areas, forums and chats or participate in any contests or any other promotional activities, and Caulfield Cables does not knowingly collect or use information from children under age 16 through this website.
To subscribe to newsletters and to participate in other activities where Personal Information is divulged on this website, you must be age 16 or older. Minors under the age of 18 are required to get the permission of their parent(s) or legal guardian(s) before subscribing to anything on this website.
If you have actively (opt-in) registered to receive Caulfield Cables communications, you may also receive commercial email regarding upcoming Caulfield Cables promotions, products and services. If you receive Caulfield Cables ' commercial email and would like to avoid receiving such email in the future, you may opt-out of receiving it by clicking on the opt-out area within that email or by clicking here. Caulfield Cables will only communicate with you according to your instructions.8. SECURITY
Caulfield Cables limits third party access to Personally Identifiable Information collected on this website. This website has security measures in place that we believe are reasonable to help protect against the loss, misuse and alteration of the information under Caulfield Cables’ control. While Caulfield Cables cannot guarantee that loss, misuse or alteration to data will not occur, Caulfield Cables uses industry standards, such as Secure Socket Layers ("SSL") technology, to help safeguard against such occurrences. In certain instances, the information passed between your browser and the Caulfield Cables system is encrypted with SSL technology to create a protected connection between you and this website to ensure confidentiality. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
9. ACCESS TO YOUR PERSONAL INFORMATION
1. Access to Your Personal Information.You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
2. Changes to Your Personal Information.We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
3. Deletion of Your Personal Information.Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
4. Objection to Certain Processing.You may object to our use or disclosure of your personal information by contacting us at the address described below.
5. Online Tracking.We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
6. Promotional Emails.You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
7. Revocation of Consent.If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
You may address any complaints to Caulfield Cables and we will take your concern very seriously. You may further lodge a complaint to your national data protection authority in cases where you deem that appropriate.
If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.11. THIRD-PARTY WEBSITES
This website may link to, or be linked to, other websites not maintained by or related to Caulfield Cables. Caulfield Cables is not responsible for the privacy policies or practices of any third parties or third-party websites, including any third-party linked or linking websites. To the extent that you disclose Personally Identifiable Information to any such third parties, different rules may apply to their use and disclosure of Personal Information that you disclose to them. Caulfield Cables encourages you to review the privacy policies of such websites before disclosing your Personal Information to them.
12. CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for that third party's direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any Personal Data with third parties for their direct marketing purposes. If we do decide to share your Personal Data with third parties for their marketing purposes, you may opt-out of this disclosure at any time by submitting a request to:
Attn: Legal Department
It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes or for purposes of assisting us with our own marketing. Additionally, if you are a registered user under the age of 18 and a resident of California, you may request removal of content you have posted to our website or social media accounts. Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain the information for our own internal records, and it is also possible that a third party we do not own or control may copy the posting and repost it elsewhere.
13. BUSINESS TRANSFERS
14. CONTACTING US
Caulfield Cables Attn: Legal Department
Effective Date: July 10, 2020