1.1 We are committed to safeguarding the privacy of Super Brush™ LLC/Swab-its® website visitors and users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of Super Brush™ LLC/Swab-its® website visitors, services and purchases; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via your account after log-in.
1.5 In this policy, "we", "us" and "our" refer to Super Brush™ LLC/Swab-its®. [ For more information about us, see Section 12.]
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website, services and purchases ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Stat Counter. This usage data may be processed for the purposes of analyzing the use of the website, services and purchases.
2.3 We may process your account data. The account data may include your name, email address, full company information and order information. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
2.4 We may process information included in your personal profile on Superbrush.com/Swab-its.com. The profile data may include your name, email address, full company information and order information. The profile data may be processed for the purposes of enabling and monitoring your use of our website.
2.5 We may process your personal data that is provided during the use of our services. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
2.6 We may process the information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services.
2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you.
2.8 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers.
2.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website Superbrush.com/Swab-its.com ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for supplying the purchased goods and services and keeping proper records of those transactions.
2.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
2.11 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Superbrush.com/Swab-its.com will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
2.12 We may process any of your personal data identified in this policy where necessary Super Brush™ LLC/Swab-its® to exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice.
2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
2.15 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies this means our subsidiaries Super Brush™ LLC, Swab-its®, Bore-tips®, Caran Precision and, our ultimate holding company JRJRC and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 Financial transactions relating to our Superbrush.com, Swab-its.com, Bore-tips.com, Shop.Swab-its.com and services are handled by our payment services providers, Authorize.net or PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We and our other group companies have offices and facilities in United States & Mexico. We will not provide your information with any offices or facilities outside the United States and Canada.
4.3 The hosting facilities for our websites are situated in United States and Canada.
4.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) personal data, purchases, purchase orders, customer inquiries will be retained.
[customers can keep an account on Swab-its.com for as long as needed]
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email.
7. Your rights
7.1 In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting www.swab-its.com when logged into our website.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by calling 1.413.543.1442, email firstname.lastname@example.org or by mail 800 Worcester Street, Springfield, MA 01151, in addition to the other methods specified in this Section 7.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
9.3 Email newsletters related cookies. This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
9.4 Orders processing related cookies. This site offers e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.
9.6 Forms related cookies. When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
9.7 Site preferences cookies. In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.
9.8 From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimizations our users appreciate the most.
10. Third Party Cookies
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
11.4 Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren't sure whether you need or not it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.
11.5 However if you are still looking for more information than you can contact us through one of our preferred contact methods:
12. Our details
12.1 This website is owned and operated by Super Brush™ LLC.
12.2 We are registered in United States and our registered office is at 800 Worcester Street, Springfield MA 01151.
12.3 Our principal place of business is at 800 Worcester Street, Springfield MA 01151.
12.4 You can contact us:
(a) by post, to Super Brush LLC/Swab-its® 800 Worcester Street, Springfield, MA 01151;
(b) using our website contact form at www.swab-its.com;
(c) by telephone, 1.413.543.1442, Monday – Friday, 8:30am – 4:30pm Eastern Standard Time; or
(d) by email, using email@example.com
13. Data protection officer
13.1 Our data protection officer's contact details are: Michael Lecrenski: firstname.lastname@example.org.
14.1 The Sites are not directed at children, and Super Brush™ LLC/Swab-its® does not knowingly collect Personal Information directly from users under the age of 13 or from other websites or services directed at children. Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will not knowingly request or collect Personal Information from any child under age 13 without obtaining the required parental consent. Children can browse the Sites without any Personal Information being collected.
14.2 The parent or legal guardian who has consented to a child providing Personal Information to one or more of the Sites may later view the child’s Personal Information and correct or remove the information, in whole or in part; instruct Super Brush™ LLC/Swab-its® to discontinue all use of the child’s Personal Information and/or not to communicate further with the child; or revoke or modify the consent, by contacting us at Customerservice@swab-its.com and including the child’s name and email address and the parent or guardian’s name and email address. Please visit http://www.ftc.gov/privacy/privacyinitiatives/childrens.html for information from the Federal Trade Commission about protecting children’s privacy online.
15. Your California Privacy Rights
15.1 Effective January 1, 2005, under California Civil Code Section 1798.83, if an individual who is a California resident has provided Personal Information to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual’s Personal Information to a third party and knows or should have known that such third party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what Personal Information was shared and with whom it was shared.
Any request for a disclosure required under this California law should be sent to us via email at email@example.com or via regular mail at the address set forth below.
Super Brush™ LLC/Swab-its®
800 Worcester Street
Springfield, MA 01151
Please note that under this law, we are not required to respond to a customer’s request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email or mailing address designated above.
16. Terms Applicable to Data from EU Member Countries
16.1 We are based in the United States. In most cases, the Personal Information we collect is stored and used in the United States.
16.2 If we collect Personal Information from EU residents in a manner subject to the General Data Protection Regulation then, in addition to the above, the following terms shall also apply to our collection, use and retention of that information:
17. Compliance with Privacy Shield Principles
17.1 When handling Personal Information from residents of the EU Member Countries, we strive to comply with the EU-U.S. Privacy Shield Framework principles (Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability) regarding the collection, use and retention of Personal Information from EU Member Countries. However, our compliance with these principles may be limited (a) to the extent necessary to meet applicable national security, public interest, or law enforcement requirements; or (b) by statute, governmental regulation, or case law. If there is a conflict between the policies set forth below and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.
18. Basis for Collection
18.1 As set out above, we collect and process Personal Information for which you have given your express consent at the time of collection. For example, we collect Personal Information when you elect to participate in one of our promotions. We also collect and process Personal Information to improve our services, to deliver services and perform obligations under contracts we have with you, and to comply with our own legal obligations.
18.2 We do not collect sensitive data, for example, biometric data, health data, or data revealing racial or ethnic origin, from visitors to the Sites.
18.4 We also may disclose Personal Information for other purposes or to other third parties when you have consented to or requested such disclosure. Please be aware that we will disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are not liable for appropriate onward transfers of Personal Information to third parties.
18.5 We may retain third parties to process or analyze Personal Information we collect from the Websites. For example, a Site may be maintained or hosted by a third party service provider, a promotion may be administered by a sales promotion agency, and/or products may be fulfilled by a wholesaler. These suppliers and other third parties who provide services for us are contractually obligated not to use Personal Information about you except as we authorize.
18.6 We may analyze Personal Information we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use Personal Information about you to detect and reduce fraud and credit risk.
18.7 Your rights include: (a) a right to withdraw your consent to the processing of Personal Information about you to which you have previously given consent; (b) a right to object to processing of Personal Information about you for the purpose of direct marketing; and (c) a right to have any incorrect part of the Personal Information about you corrected or removed.
18.8 If you request to have incorrect Personal Information removed, we may retain some of your Personal Information as necessary for the purposes of our legitimate business interests or in furtherance of public interests in accordance with the Privacy Shield Principles. Any Personal Information you have shared publicly with others may continue to be publicly visible on the Sites.
18.9 You also have the right to obtain a copy of the Personal Information we have about you, although we reserve the right to charge a reasonable fee for this depending on the nature and frequency of your request(s) and our cost to provide the information.
19. Questions and Complaints
19.2 In compliance with the EU-U.S. Privacy Shield and the US Swiss Safe Harbor Principles, we commit to resolve complaints about your privacy and our collection or use of your Personal Information. If you do not receive timely acknowledgement of your request or have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
19.3 In addition to the above, you may complain to your home data protection authority and can invoke binding arbitration for some residual claims not resolved by other redress mechanisms. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
20. Third Party Websites
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