Effective Date: December 2019
I. Corporate Commitment to Privacy
Hunter Industries, Inc. (U.S.A. Headquarters, 1940 Diamond Street, San Marcos, CA 92078, USA, Phone: (1) 760-744-5240, Email: Privacy@hunterindustries.com), its subsidiaries, and affiliates ("Hunter Industries", "we" or "us") are committed to respecting your privacy. A list of all relevant Hunter Industries affiliates is available under BRANDS AND PRODUCTS. This Privacy Notice describes how we collect, use, disclose, store, and otherwise process information when you use our websites and other online products and services. When this document refers to "Hunter Industries" both, the local Hunter entity which is your contractual party and the wider Hunter industries group of companies is meant. Depending on which entity is responsible for the processing of Personal Data and the underlying systems, the Hunter Industries company which contracts with you (according to your contract) and/or Hunter Industries, Inc. are the data controllers of your Personal Data, which means that they determine what Personal Data is needed and how it should be used.
We encourage you to read this Privacy Notice so that you understand our commitment to you and your privacy, and how you can participate in that commitment.
Hunter Industries complies with privacy laws and in particular the General Data Protection Regulation (Regulation (EU) 2016/679, hereafter "GDPR") and the California Consumer Privacy Act of 2018 (AB 275, Title 1.81.5, hereafter "CCPA"). The GDPR mandates that Hunter Industries protects the Personal Data and privacy of European Union residents. The CCPA mandates that Hunter Industries protects the Personal Data and privacy of California residents. Where these two privacy legal frameworks diverge, we will follow the framework that provides you with a higher degree of privacy.
Personal Data within the above meaning refers to any information relating to an identified or identifiable natural person or household, such as real name, an identification number, email address, home address, Internet Protocol address, employment related information, or identifiers of physical, mental, economic, cultural, and social characteristics ("Personal Data").
II. Scope of this Privacy Notice
Hunter Industries has established and implemented this Privacy Notice to inform visitors of the website and users of our services (including Business Partners transacting and Applicants applying with us) how we use and protect the information we collect from our websites and in relation to our products and services.
Therefore, in this Privacy Notice ("Privacy Notice"), we describe how we collect, use, and disclose Personal Data that we obtain (i) about our distributors, suppliers, vendors and partners ("Business Partner"), where the Business Partner is an individual protected by data protection law, about (ii) the current and future contact persons and other persons the Business Partner engages in the context of the business relationship with us, about (iii) Applicants who apply through our website ("Applicants"), and about (iv) users of our website only surfing on it ("Website User") (together, (i), (ii), (iii) and (iv), are referred to as "Concerned Individuals" in this policy).
III. Personal Data we process about our Concerned Individuals
1. Business Partners
In the context of a business relationship we may process the following Personal Data about you as our Business Partner:
- Contact information, such as full name, postal work address, work telephone number, work cell/mobile phone number, work fax number and work email address, and job title.
- Payment data, such as credit/debit card numbers, security code numbers, tax ID and other related billing information and data necessary for processing payments and fraud prevention;
- Further information necessarily processed in a project or contractual relationship with us or voluntarily provided by the Business Partner, such as Personal Data relating to orders placed or payments made;
- Personal Data collected from publicly available resources; and
- Other Personal Data, if such Information is required by us for compliance screenings of Business Partner in line with data protection law. This may include date of birth, ID numbers, identity cards and information about relevant and significant litigation or other legal proceedings against Concerned Individuals.
For the purpose of this Privacy Notice, Personal Data of Applicants includes:
- mandatory information such as name, contact details, location address, gender, citizenship, eligibility to work in certain countries and notice period;
- as well as additional information you may volunteer to further provide information on your application, such as work competencies, work experience, education and certifications, references, cover letter, job preferences, personal context in case of relocation, and related uploaded documents;
- your ethnicity where required or permitted by law.
3. Website User
We gather certain technical information that includes anonymous usage statistics for the purpose of improving our services., which your web browser automatically sends when you visit any website on the internet. "Technical Information" is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. Our servers automatically record this information, which may include your Internet Protocol ("IP") address, browser type, browser language, and the date and time of your request. When required to authenticate to our website, we may process the following Personal Data about you as our Website User:
- mandatory information required to process your log in such as full name and email address;
- contact information necessary to validate your eligibility for certain online services, such as full name, postal work address, work telephone number, work cell/mobile phone number, work fax number, and job title; and
- additional information you may volunteer to further provide.
IV. How we use Personal Data of our Concerned Individuals
1. Business Partner
We process Personal Data of Business Partners for the following purposes:
- To communicate with you about products and services, or to respond to your queries or requests;
- To establish and fulfill a contract with you, a request for quotation or a purchase order. This may include performing transactions and orders verifying your identity, communicating with you, providing customer services, processing payments, performing accounting, auditing, billing and collection, as well as arranging the shipment or other provision of products, goods or services;
- To enable our business and pursue our legitimate interests, in particular to respond to any comments or inquiries you may send us;
- To administer and perform marketing campaigns, surveys, market analysis, contests, sweepstakes or other promotional activities or events; or
- To comply with applicable laws (such as record keeping obligations), export control and customs, compliance screening obligations (e.g. to prevent white-collar or money laundering crimes), and to protect our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, especially regulatory or investigative purposes (including disclosure of such information in connection with a legal process or litigation).
We process Personal Data of Applicants for the following purposes:
- To administer, process and evaluate the application of the concerned Applicant or to assess its suitability for available roles based on the profile created;
- If an Applicant provides the details of a reference or any other third party e.g. educational institution as part of the application, it authorize us to contact the said person or organization to validate any information provided and related to the relevant work experience and qualifications of the Applicant. The submitting Applicant warrants to us that it has such authorization;
- During the recruitment process we may ask the Applicant to provide us with additional information or request additional consent allowing us to conduct pre-employment checks to further assess the Applicant’s qualifications and suitability for the role it applied for or for other roles;
- To comply with applicable laws (such as record keeping obligations), export control and customs, compliance screening obligations, and to protect our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, especially regulatory or investigative purposes (including disclosure of such information in connection with a legal process or litigation).
3. Website User
We process Personal Data of Website Users for the following purposes:
- Gathering technical information helps us ensure our websites and other services work correctly;
- To validate your access to online services (when required to log in); and
- To administer and perform marketing campaigns, surveys, market analysis, contests, sweepstakes or other promotional activities or events.
V. Legal Basis for Our Processing of Personal Data of Concerned Individuals
Unless expressly stated otherwise, when we process Personal Data from Concerned Individuals, the legal basis for the processing is provided below:
- if we process the Personal Data in connection with a contract with you (GDPR, Art. 6 para 1b);
- if we process the Personal Data to enable our business and pursue our legitimate interests. Our legitimate interest is to communicate with you about products and services or to respond to your queries or requests and to efficiently perform or manage our relationship with you (GDPR, Art. 6 para 1f);
- if we process the Personal Data to comply with legal obligations we are subject to (GDPR, Art. 6 para 1c);
- if we process the Personal Data upon your consent, e.g. for personalized marketing communications. You have the right to withdraw the consent at any time. The consent can be withdrawn by emailing Privacy@hunterindustries.com or, in case of electronic direct marketing, by following the instructions in the communication (GDPR, Art. 6 para 1a).
VI. How We Disclose Personal Data of Concerned Individuals
We may disclose Personal Data of Concerned Individuals to the following third parties, in each case always only in accordance with applicable data protection laws:
- Affiliates. We may disclose Personal Data to current or future affiliates or subsidiaries meaning any company, corporation or other entity that directly or indirectly controls, or is controlled by, or is under common control with Hunter Industries, Inc. for research, marketing, and any other of the abovementioned purposes.
- Government Authorities/ Law Enforcement Officials. Personal Data may be shared with government authorities or law enforcement officials if required for the purposes above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws.
VII. Transfer of Personal Data of Concerned Individuals to a third country
When Personal Data is transferred from the European Economic Area to outside the European Economic Area, appropriate safeguards (e.g., EU standard contractual clauses or Privacy Shield certification) will be used to ensure an adequate level of protection of the concerned Personal Data. For further information on or a copy of the aforementioned safeguards, please email Privacy@hunterindustries.com.
VIII. How Long we Retain Personal Data of Concerned Individuals
In principle, we will keep Personal Data of Concerned Individuals for as long as it is necessary for our relationship or otherwise allowed or required under applicable law. If we are processing a specific request you sent us, we will generally keep the concerned Personal Data for as long as is necessary to process this request. Afterwards, we may retain Personal Data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the concerned Personal Data for specific periods. If we process Personal Data based on consent, we will delete this Personal Data upon withdrawal of the consent. Any deviating retention period will be specified when we collect the Personal Data is collected (e.g. when we ask for consent).
Once the purpose for which the Personal Data was initially collected is achieved and the retention period ended, we will delete or anonymize it in a secure manner without unreasonable delay.
If we cannot entirely delete Personal Data due to statutory retention obligations or billing and accounting obligations, the Personal Data will be blocked until the respective retention period expired or until the billing or accounting purpose has been fulfilled, meaning that the Personal Data is excluded from further use.
IX. Choice: Privacy Rights of Concerned Individuals
Hunter Industries gives you choices about the ways we collect, use, and share Personal Data of you as Concerned Individuals. You can choose what contact and financial information will be stored in your account and preferences. However, if you choose not to provide certain details, some of your experiences with us may be affected.
1. Access to and Correction of Personal Data
Hunter Industries provides you with many opportunities to access and update your Personal Data. You can ensure that any account, contact, or financial information is current and can correct, update, or delete inaccuracies to the information. In some cases, however, we may limit or deny your request if the law permits or requires us to do so, infringes on the privacy of other individuals or internal procedures, or if we are unable to verify your identity.
2. For European Union residents
In respect of the collection and use of your Personal Data, you may:
- withdraw your consent at any time for example by unsubscribing from newsletters,
- ask us whether we processes Personal Data about you, for which purposes, the categories of Personal Data concerned, to which categories of recipients the information has been disclosed, where possible, the envisaged period for which the Personal Data will be stored (or, if not possible, the criteria used to determine that period),
- inquire with us about the appropriate safeguards relating to the transfer to a third party,
ask us for a copy of the Personal Data undergoing processing and ask to receive your Personal Data in a structured, commonly used and machine-readable format and to transmit those data to another controller without any hindrance from us.,
- have inaccurate data rectified,
- object against the further processing and request erasure of your Personal Data,
- request that the processing of your Personal Data is restricted by us,
- request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
With regard to these rights some restrictions apply. For example, we cannot delete Personal Data if we are obliged to store it by law or if we retain it based on a contract with you or the Concerned Individual. In addition, information about and access to Personal Data may be denied if Personal Data about another person would be disclosed with the provision of the information or if it is not possible for us to disclose the concerned Personal Data for legal reasons.
If Personal Data is required by us to fulfil a legal or contractual obligation, providing this information is mandatory: If this information is not provided, we cannot perform the contract or fulfil our obligations. In all other cases, the provision of the requested Personal Data is voluntary.
If you have any concerns about how we process Personal Data, or would like to opt out of marketing, one can get in touch at Privacy@hunterindustries.com.
A Concerned Individual may always lodge a complaint with a supervisory authority, in particular with the supervisory authority in the EU Member State that it resides in.
3. For California residents
With respect to the collection and use of your Personal Data, you may after we reasonably verify your identity:
- ask us whether we process Personal Data about you, for which purposes, the categories of Personal Data concerned, to which categories of recipients the information has been disclosed, where possible, the envisaged period for which the Personal Data will be stored (or, if not possible, the criteria used to determine that period),
- request erasure of your Personal Data,
- request to opt-out from sale of your Personal Data to 3rd party (Please note that we do not sell your Personal Data to third parties).
You have a right to equal service and price, even if you exercise your privacy rights.
With regard to these rights some restrictions apply. For example, we may not delete Personal Data:
- if we are obliged to store it by law. In addition, information about and access to Personal Data may be denied if Personal Data about another person would be disclosed with the provision of the information or if it is not possible for us to disclose the concerned Personal Data for legal reasons.
- if it is required by us to complete a transaction, to provide a good or service requested by you, or reasonably anticipated within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between the business and you;
- if it enables solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
If you have any concerns about how we process Personal Data, or would like to opt out of marketing, you can get in touch at Privacy@hunterindustries.com.
We use the following categories of cookies on our website:
Category 1: Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or data provided for a booking cannot be provided.
Category 2: Performance Cookies
These cookies collect information on how people use our website. For example, we use Google Analytics cookies to help us understand how users arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, booking experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
Category 3: Functionality Cookies
These cookies remember choices you make such as the country you visit our website from, language and search parameters. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant.
Current versions of web browsers offer enhanced user controls regarding the placement and duration of both first and third party cookies. Search for "cookies" under your web browser's "Help menu" for more information on cookie management features available to you. You can enable or disable cookies by modifying the settings in your browser. You can also find out how to do this, and find more information on cookies at www.allaboutcookies.org. However, if you choose to disable cookies in your browser, you may be unable to complete certain activities on our websites or to correctly access certain parts of it. If you would like more information about interest-based advertising, including how to opt-out of these cookies, please visit http://youronlinechoices.eu/.
XI. Google Analytics
Our website and software applications for mobile devices use Google Analytics, which is a web analytics service provided by the third party provider Google, Inc. ("Google"). Google Analytics is used for the purpose of evaluating your use of our website, compiling reports on website activity and other services relating to website activity and internet usage. The information generated by the cookie about your use of the website is usually transmitted to and stored by Google on servers in the United States. This transfer is covered by Google’s Privacy Shield certification and a separate data processing agreement that we have concluded with Google. On this website we have also activated the IP anonymization tool "gat._anonymizeIp();" provided by Google to help protect your privacy. This means that your IP address will automatically be shortened after it is collected so it can no longer be connected to you (see https://support.google.com/analytics/answer/2763052). For more information see https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631 (information on Google Analytics and data privacy).
XII. Data Security
Security of all information is of the utmost importance. Hunter Industries uses technical and physical safeguards to protect the security of your Personal Data from unauthorized disclosure. We make all attempts to ensure that only necessary individuals and third parties have access to Personal Data. Nevertheless, such security measures cannot prevent all loss, misuse, or alteration of Personal Data, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the case of a data breach, we will notify you through our on-file contact information of any loss, misuse, or alteration of Personal Data that may affect you.
XIII. Security Measures to Protect Personal Data by Third Parties
We require that our third-party service providers and channel partners keep all information confidential. They may only use the information to perform their obligations in the agreements we have in place with them. These third-party service providers and channel partners are expected to maintain privacy and security protections that are consistent with Hunter’s data protection and information security policies.
XIV. Children’s Information
We do not knowingly solicit data from or market to children under the age of 18. Any parent or guardian who becomes aware that their child has provided us with information without their consent should contact us at firstname.lastname@example.org. We will delete such information from our files within a reasonable time after confirmation.
This Privacy Notice is current as of the Effective Date set forth above. We may change this Privacy Notice from time to time and we will post any changes to this Privacy Notice on this website.
XVI. Questions/Updates to Policy
Hunter Industries commits to resolve complaints about your privacy and our collection/use of your Personal Data. If you have an inquiry or complaint regarding this Privacy Notice, please contact Hunter’s Data Protection Officer at 1940 Diamond Street, San Marcos, CA 92078 or Privacy@hunterindustries.com.
Toll Free Number: 1-866-221-3268