Last Updated: May 22, 2018

 

SECTION 1 - PURPOSE

We at Empire Abrasives are providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our Services. This Privacy Policy is incorporated by reference into the Empire Abrasives Terms of Service (the “Terms”). The terms “Empire Abrasives,” “we,” and “us” include Empire Abrasives and our affiliates and subsidiaries.

This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information. The intent of this document is to both comply with United States and EU (GDPR) Privacy requirements but also inform and educate our global customer base as to our data practices. We believe that all customers have a “right to be forgotten” and will comply to our best ability with such requests.

 

SECTION 2 – TYPES OF INFORMATION WE COLLECT

Empire Abrasives collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors and guests. (collectively “Individuals”).

Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with Empire Abrasives, making an online or in-store purchase, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

Creating an Account with Us. When you make a purchase online or in an Empire Abrasives store, we will automatically create an Account for you. To create an Account, we’ll collect certain information that can be used to identify you, such as your name, postal address and phone number, as well as other optional information you may provide like the type of abrasives you prefer.

Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, create an account, register for Empire Abrasive’s newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.

From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.

Posting on the Site. You may post reviews of your purchases on Empire Abrasive’s Site. You should be aware that, when you disclose information about yourself in on Empire Abrasive’s Site, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

Registration for Sweepstakes or Contests. Occasionally, Empire Abrasives may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt-out of any communications that are not related to awarding prizes.

Automatic Data Collection. Our servers automatically record certain information about how Individuals use our Services (we refer to this information as “Event Data”). Event Data may include information such as an Individual’s Internet Protocol (IP) address, cookie identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, operating system, browser type and language, hardware type, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Event Data to administer the Services and we analyze (and may engage third parties to analyze) Event Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to Individuals’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.

Location Information. We may collect and store information about your location by converting your IP address into a rough geo-location. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

Information Submitted Via Services. You agree that Empire Abrasives is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Empire Abrasives will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

 

SECTION 3 - WHAT DO WE DO WITH YOUR INFORMATION?

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested. Empire Abrasives may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:

• Generally manage Individual information and Accounts;
• Respond to questions, comments, and other requests;
• Provide access to certain areas, functionalities, and features of Empire Abrasives’ Services;
• Contact you to answer requests for customer support or technical support;
• Allow you to register for events.
• Administrative Purposes. Empire Abrasives may use Personal Information about you for its administrative purposes, including to:
• Measure interest in Empire Abrasives’ products and Services;
• Develop new products and Services;
• Ensure internal quality control;
• Verify Individual identity;
• Communicate about Individual Accounts and activities on Empire Abrasives’ Services and systems, and, in Empire Abrasives’ discretion, changes to any Empire Abrasives policy;
• Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
• Process payment for products or services purchased;
• Process applications and transactions;
• Prevent potentially prohibited or illegal activities;
• Enforce our Terms.
• Marketing Empire Abrasives Products and Services. Empire Abrasives may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Empire Abrasives may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
• To tailor content, advertisements, and offers;
• To notify you about offers, products, and services that may be of interest to you;
• To provide Services to you and our sponsors;
• For other purposes disclosed at the time that Individuals provide Personal Information; or Otherwise with your consent.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.

Research and Development. We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes. We may contract with third parties who provide us with other information about you, which we may then combine with the information we receive from you. We use this information to better provide our Services, to customize our advertisements to you and other customers, and to provide direct marketing to you, including by mail.

From time to time, Empire Abrasives may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.

Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Empire Abrasives’ or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 4 below.

Services via Mobile Devices. From time to time, Empire Abrasives may provide Services that are specifically designed to be compatible and used on mobile devices. Empire Abrasives will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Empire Abrasives’ Services may require that users log in with an Account. In such cases, information about use of mobile versions of the Services may be associated with Accounts. In addition, Empire Abrasives may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Empire Abrasives to enable Individuals to access Accounts and to enable Empire Abrasives to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Empire Abrasives may use personal or non-identifiable information transmitted to Empire Abrasives to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Empire Abrasives provides.

Anonymous and Aggregated Information Use. Empire Abrasives may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Empire Abrasives’ Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Empire Abrasives may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Empire Abrasives and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

Sharing Content with Friends or Colleagues. Empire Abrasives’ Services may offer various tools and functionalities. For example, Empire Abrasives allows you to provide information about your friends through our referral services, such as “Invite a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Empire Abrasives or any other Third Parties for any other purpose.

Other Uses. Empire Abrasives may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Social Media Widgets: Our Website includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;

Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;

Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

 

SECTION 4 - CONSENT

How do you get my consent?

When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

How do I withdraw my consent?

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at sales@empireabrasives.com or mailing us at:

Empire Abrasives            

85B Hoffman Lane,

Islandia, NY 11749

 

SECTION 5 - DISCLOSURE

We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.

 

SECTION 6 - THIRD-PARTY SERVICES

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our store’s website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.

Links

When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

 

SECTION 7 - SECURITY

We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use, or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

 

SECTION 8 - Opt-Out (RIGHT TO RESTRICT PROCESSING)

We offer you choices regarding the collection, use and sharing of your Personal Information, and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services. You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Empire Abrasive’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting sales@empireabrasives.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Empire Abrasives and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

SECTION 9 - COOKIES

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your computer browser, that opt out will not be effective on your mobile device. You must separately opt out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

 

SECTION 10 – INTERNATIONAL USERS

We consider ourselves compliant with the EU GDPR standards. Regardless, by using the Site, Empire Abrasives will transfer data to the United States. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of New York, United States and the adjudication of any disputes arising in connection with Empire Abrasives or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

 

SECTION 11 - AGE OF CONSENT

The Services are not directed to children under 16 years of age, and Empire Abrasives does not knowingly collect Personally Identifiable Information from children under 16 years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. If you learn that your child has provided us with Personal Information without your consent, you may alert us at sales@empireabrasives.com. If we learn that we have collected any Personal Information from children under 16, we will promptly take steps to delete such information and terminate the child’s Account.

 

SECTION 12 - CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.

 

QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at sales@empireabrasives.com or mailing us at:

Empire Abrasives

85B Hoffman Lane

Islandia, NY 11749