Privacy Notice
Last modified: April 2024
HAVI Group, LP, and our subsidiaries and affiliates (“HAVI”, “us”, “we”, or “our”) respect your privacy and commit to protecting your personal data as described in this notice. This notice describes our practices for collecting, using, storing, protecting, and sharing the personal data we may collect from you or that you may provide when you visit our websites or other digital properties, communications, or forms that link or refer to this notice (our “Website”).
Please read this notice carefully to understand our practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this notice. This notice may change occasionally. Your continued engagement with our Website after any revisions indicates that you accept and consent to them, so please check the notice periodically for updates.
Table of Contents
- Privacy Notice Scope and General Introductions
- What Personal Data is Collected
- General Audience Website
- How Personal Data is Collected
- Cookies and Automatic Data Collection Technologies
- Third-Party Use of Cookies and Other Tracking Technologies
- How Personal Data is Used and Shared
- Cross-Border Personal Data Transfers
- Data Security
- Data Retention
- Your Rights and Options
- Your Personal Data Use Choices
- Accessing and Correcting Your Personal Data
- Disclosures for Specific Jurisdiction
- European Economic Area and the United Kingdom Disclosures
- U.S. State Data Privacy Disclosures
- Data Privacy Contact
- Privacy Notice Revisions and Updates
- Contact Information
- Privacy Notice Scope and General Introductions
This notice describes our practices for collecting, using, storing, protecting, and sharing the personal data we may collect from you or that you may provide when you visit our Website. This notice applies to the personal data collected through our Website, despite the country where you are located.
This policy does not apply to third-party websites. The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.
- What Personal Data is Collected
Personal data means any information relating to an identified or identifiable natural person. We may collect different categories of personal data from and about you including:
- Identity data such as your first name, last name, any previous names, username or similar identifier, date of birth, and gender.
- Contact data such as your billing address, delivery address, email address, and telephone number.
- Technical data such as the internet protocol (“IP”) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.
- Usage data details about your Website interactions, including the full Uniform Resource Locators (“URL”), clickstream information to, through, and from our Website (including date and time), products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.
We also collect non-personal data that does not reveal your identity, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
If we combine or connect non-personal, demographic, or technical data with personal data so it identifies an individual, we treat the combined information as personal data.
- General Audience Website
We do not direct our Website to minors, and we do not knowingly collect personal data from children under 13 or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us.
- How Personal Data is Collected
We use different methods to collect data from and about you including through:
- Your direct interactions with us. You may give us your personal data by filling in forms or by corresponding with us by phone, email, or otherwise. This includes data you provide when you create an account, subscribe to our service, participate in discussion boards or other social media functions on our Website, enter a competition, promotion, or survey, and report a problem with our Website.
- Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions, and patterns as specified above. We collect this data by using cookies, web beacons, server logs, and other similar technologies.
- Third parties or publicly available sources. We may receive data about you if you visit other websites using our cookies or from third parties, including business partners, service providers in technical, payment, and delivery services, advertising networks, analytics providers, and search information providers.
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- The Website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
- Cookies and Automatic Data Collection Technologies
Our Website uses cookies, web beacons, embedded scripts, or other automatic data collection technologies to distinguish you from other Website users. This helps us to provide you with a good experience when you browse our Website. It also lets us improve our Website by enabling us to:
- Estimate our audience size and usage patterns.
- Store your preferences so we may customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
Cookies
A cookie is a small file of letters and numbers we may store on your browser or the hard drive of your computer if you agree. Cookies contain information transferred to your computer’s hard drive. We use these cookies:
- Strictly necessary cookies. These are cookies required for the operation of our Website. These essential cookies are always enabled because our Website won’t work correctly without them. They include, for example, cookies that enable you to log into secure areas of our Website. You can switch off these cookies in your browser settings, but you may then not be able to access all or parts of our Website.
- Analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our Website when using it. This helps us to improve the way our Website works, for example, by making sure users are finding what they are looking for easily.
- Functionality cookies. These are used to recognize you when you return to our Website. This enables us to personalize our content for you, greet you by name, or remember your preferences (e.g., your choice of language or region).
- Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests.
You may refuse to accept browser cookies by activating the proper setting on your browser. However, if you select this setting, certain parts of our Website may become inaccessible and certain features may not work correctly.
Web Beacons
Web beacons are small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs. Web beacons allow us, for example, to count website page visitors or email readers or to compile other similar statistics, such as recording Website content popularity or verifying system and server integrity.
Embedded Scripts
An embedded script is a programming code designed to collect information about your interactions with the Website, such as the links you click on. The code is temporarily used by our server or a third-party service provider or business partner while you browse or interact with the Website and is deactivated or deleted when you disconnect from our Website.
Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or with web beacons or other tracking technologies to collect information about you when you use our Website. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based behavioral advertising or other targeted content.
We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have questions about an advertisement or other targeted content, contact the responsible provider directly.
- How Personal Data is Used and Shared
We use your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:
- Present our Website and provide you with the information, products, services, and support you request from us.
- Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or complying with legal requirements.
- Fulfill the purposes for which you provided the data or that were described when it was collected.
- Notify you about changes to our Website, products, or services.
- Ensure that we present our Website content in the most effective manner for you and for your computer.
- Administer our Website and conduct internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
- Improve our Website, products or services, marketing, or customer relationships and experiences.
- Enable your participation in our Website’s interactive, social media, or other similar features.
- Protect our Website, employees, or operations.
- Measure or understand the effectiveness of the advertising we serve to you and others and deliver relevant advertising to you.
- Make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
We may share your personal data with:
- Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
- Business partners, suppliers, service providers, subcontractors, and other third parties we use to support our business (such as analytics and search engine providers that help us with Website improvement and optimization). We contractually require these third parties to keep that personal data confidential and use it only for contracted purposes.
- Advertisers and advertising networks that require the data to select and serve relevant ads to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may give them aggregate information about our users.
- For any other purposes we disclose in writing when you provide the data.
- With your consent.
We may also disclose your personal data to third parties:
- To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- To enforce or apply our terms of use, terms of sale, and other agreements.
- To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for cybersecurity, fraud protection, and credit risk reduction.
- Cross-Border Personal Data Transfers
We may transfer the personal data we collect about you to jurisdictions that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this privacy notice. We have implemented appropriate legal mechanisms, including data transfer agreements such as Data Processing Agreements (“DPA”), Standard Contractual Clauses (“SCC”), and Transfer Impact Assessments (“TIA”), to secure the transfer of your personal data to other jurisdictions.
By submitting your personal data or engaging with our Websites, you consent to this transfer, storing, or processing.
- Data Security
The security of your personal data is important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all personal data you provide to us behind firewalls on servers using security protections.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data sent to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures on the Website.
- Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it, including to satisfy any legal, regulatory, accounting, or reporting requirements. We may keep your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation regarding our relationship with you. Otherwise, we will retain and securely destroy your personal data in accordance with our document retention policy and applicable laws and regulations.
- Your Rights and Options
- Your Personal Data Use Choices
We strive to give you choices regarding certain personal data uses, particularly around marketing and advertising. We have established these personal data control mechanisms:
- Promotional Offers from the Company. If you do not want us to use your contact information to promote our own products and services, or third parties’ products or services, you can opt-out by replying to any promotional email we have sent you or following the opt-out links on that message.
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this Website may become inaccessible or not function properly.
- Targeted Advertising. If you do not want us to use personal data we collect or that you provide us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out. Some of these third parties may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. Both NAI and DAA provide information regarding procedures for opting-out of targeted online advertising from participating companies. For this opt-out to function, you must have your browser set to accept browser cookies.
Our Website may occasionally have links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, these third parties have their own privacy policies. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.
- Accessing and Correcting Your Personal Data
By law, you may have the right to request access to, correct, or erase the personal data we hold about you, or object to the processing of your personal data under certain circumstances. To review, verify, correct, request erasure of your personal data, or object to the processing of your personal data, please contact us. Any such communication must be in writing. Depending on the jurisdiction where you are located, some of these rights may not apply.
We may ask for specific information from you to help us confirm your identity, verify your rights, and respond to your request, including providing you with the personal data we hold about you, if applicable. Applicable law may allow or require us to deny your request, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot respond to your request, we will inform you of the reasons, subject to any legal or regulatory restrictions.
- Disclosures for Specific Jurisdictions
- European Economic Area and the United Kingdom Disclosures
This section of our privacy notice applies to the European Economic Area/European Union and United Kingdom residents and contains information about your rights under the General Data Protection Regulation (“GDPR”). This section supplements the privacy notice.
We collect and use your personal data only when we have a valid legal basis to do so. Depending on the circumstance, we may rely on one or more of these legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example, to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example, if you subscribe to an email newsletter.
You have a number of rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we must erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may show we have compelling legitimate grounds to process your information which overrides your right to object.
- Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information you provided your consent for us to use or where we used the information to fulfil a contract with you.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of these scenarios:
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- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise the rights set out above, please contact us.
In addition to the contact details in this privacy notice, users from the EU/EEA may also contact our local representative in the EU at:
HAVI Logistics Business Services GmbH
Geitlingstr. 20
47228 Duisburg
Germany
Email: info.is@havi.com
Telephone: 0049 2065 695 04
- U.S. State Data Privacy Disclosures
This section of our privacy notice applies to U.S. residents and contains information about your rights under applicable U.S. state data privacy laws, including the California Consumer Privacy Act (“CCPA”). This section supplements the privacy notice.
We collect categories of personal data to support our business operations, including providing our goods and services, in accordance with applicable U.S. state data privacy laws, including the CCPA.
We do not collect sensitive personal data. Sensitive personal data is a subtype of personal data consisting of specific information categories. While we may collect data that falls within some sensitive personal data categories, such as account log-in or citizenship (e.g., username and password or precise physical location), applicable U.S. state data privacy laws do not treat this data as sensitive because we do not collect or use it to infer characteristics about you.
We do not sell the personal data we collect or share it with third parties for cross-context behavioral advertising.
California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
- Confirm whether we process their personal data.
- Access and delete certain personal data.
- Correct inaccuracies in their personal data, considering the information’s nature processing purpose (excluding Iowa and Utah).
- Data portability.
- Opt-out of personal data processing for:
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- targeted advertising (excluding Iowa);
- sales; or
- profiling to further decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
- Either limit (opt-out of) or require consent to process sensitive personal data.
Nevada gives its residents a limited right to opt-out of certain personal data sales. However, please know we do not sell data triggering that statute’s opt-out requirements.
We do not collect sensitive personal data, and we do not sell personal data. So we do not offer a way to opt-out of the sale of personal data or limit the use of sensitive personal data. To exercise these rights please contact us.
- Data Privacy Contact
Our Data Privacy Committee (“DPC”) oversees compliance with this privacy notice. If you have questions about this privacy notice or how we handle your personal data or would like to request your personal data, please contact the DPC at dataprivacy@HAVI.com. If you are unsatisfied with our response to any issues you raise with the DPC, you may have the right to make a complaint with the data protection authority in your jurisdiction.
- Privacy Notice Revisions and Updates
We reserve the right to update this privacy notice. We will post any changes we may make on this page. If the changes materially alter how we use or treat your personal data we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. Please check back frequently to see any updates or changes to our privacy notice.
- Contact Information
Please address questions, comments, and requests regarding this privacy notice and our privacy practices to the DPC at dataprivacy@HAVI.com. If you would prefer to contact our external data privacy office directly, reach out to dpo@hewardmills.com.
Our corporate headquarter is at:
The HAVI Group, LP
345 N Morgan St. Ste 1000
Chicago, Illinois 60607 U.S.