Effective: October 1, 2023.
- Collection of Information
Information You Provide Directly to Us. When you access certain parts of the Website or engage our Services, you may directly provide personal information to Safety Marking, including contact information such as name, email, mailing address and phone number. For example, you may provide us with this information when registering for an event or seminar (such as our Learning Academy), subscribing to a newsletter or other publication that we offer, by using our Contact Us or Request a Quote pages, or engaging with our Services.
Customer Information. If you are a customer, you may provide us certain personal information if you enter into a contract with us. While this information may primarily comprise information about a business or entity, it could contain contact information such as name and email address.
Recruiting Information. If you apply for a job with our organization, including through any careers page of the Website, discuss a potential job opportunity with us or attend one of our recruiting events or interviews, we may collect information such as name, phone number, email address, educational background and job history (or other curriculum vitae information). This information may be collected in a variety of ways, including directly from you or via a third party such as a recruiting agency, educational institution, prior employer, professional reference or credentialing and licensing organization.
Social Media. When you engage with one of our social media pages, we may collect information about you, including from tracking pixels. These pixels provide non-identifiable and anonymous data (e.g., demographic information) regarding how users interact with such pages. You may opt out of this tracking in some cases by changing the privacy settings on your social media account. For information on LinkedIn’s privacy settings, see https://www.linkedin.com/psettings/. For information on Facebook’s privacy settings, see https://www.facebook.com/help/213802165366955/?helpref=related_articles. For information on Instagram’s privacy settings, see https://help.instagram.com/196883487377501. For information on Twitter’s privacy settings, see https://twitter.com/settings/account/personalization. For information on YouTube’s privacy settings, see https://www.youtube.com/howyoutubeworks/user-settings/privacy/.
Information from Public Sources. We may collect your personal information from publicly available sources such as public governmental databases. Note that if you post personal information to a publicly available portion of the Website or via our social media pages, you understand and acknowledge that such information may be made available to other users or the general public. We may combine personal information collected from public sources with other personal information we receive or collect.
Information from Private Sources. We may collect your personal information from various private sources outside of Safety Marking, including governmental entities. We may combine personal information collected from private sources with other personal information we receive or collect.
- Use of Information
We and our service providers may use your personal information for a variety of purposes permitted under applicable law, which may include, but is not limited to, the following business purposes:
- To provide you with Services and otherwise respond to your inquiries and requests.
- To provide you with marketing materials, newsletters, publications, events and seminars that you have requested, enrolled in or opted into.
- To improve or modify the Services.
- To analyze the effectiveness of our Services and our marketing efforts.
- To meet legal and regulatory requirements and to respond to legal orders.
- To keep records of our interactions with you.
- For auditing purposes.
- To monitor for fraud.
- To monitor for and debug technical issues.
- To monitor for security events (including cybersecurity issues).
- For any other purpose with your consent.
In each case, we will use your personal information only to the extent: (i) we have your consent to use such information for a given purpose; (ii) it is necessary to perform a contract between you and Safety Marking; (iii) it is necessary to comply with a legal obligation; and/or (iv) it is necessary for the purpose of Safety Marking’s or a third party’s legitimate business interests (provided that such interests are not in conflict with your rights under applicable law).
- Disclosure of Information
- Website providers or hosts
- Cloud service providers (or other data storage providers)
- Various information technology (IT) support vendors
- Software and other technology service providers
- Marketing firms
- Insurance agencies
- Accounting firms
- Consulting firms
- Business partners
We may disclose your personal information if we have a legal obligation to do so, including if needed to:
- Comply with applicable law.
- Respond to or cooperate with requests from governmental entities or law enforcement.
- Protect the rights, property or safety of Safety Marking, our users (including customers) or the public.
- Google Analytics
- Do Not Track
Your browser may offer you a “Do Not Track” option, which allows you to signal that you do not want them to track your online activities. The Website does not currently support Do Not Track requests.
- Storage and Retention of Information
We retain personal information for as long as necessary for the purposes that such information was obtained. We use the following criteria to determine the length of the retention period: the duration of our relationship with you (including if you are a customer), whether there are legal requirements to retain the information, and whether we deem retention necessary in connection with potential legal claims or positions.
- Protection of Information
Safety Marking takes commercially reasonable steps designed to protect personal information that you provide us by employing appropriate physical, technical and administrative security measures. Despite the security procedures we employ, you should be aware that it is impossible to guarantee the security of information that you transmit to us via the Internet. Your transmission of your personal information to us via the Website is done entirely at your own risk.
- Third-party Websites
- International Transfers and EEA Rights
We do not promote, market or direct Services to minors. As a result, Safety Marking does not knowingly collect or solicit personal information from anyone under the age of 18. By using our Website or by providing us your personal information, you represent that you are not under 18 years of age.
- California Legal Rights; California Job Applicants
- Notification of Changes
- Opt-Out; Contact Us
CALIFORNIA PRIVACY ADDENDUM
Safety Marking provides the following additional details to California residents and households in connection with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”) (collectively, the CCPA and CPRA, the “California Privacy Laws”).
A. Categories of Personal Information Collected
(i). Identifiers, such as your name, preferred name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, date of birth and other similar identifiers.
(ii). Personal information classifications contained in the California Customer Records statute, such as your name, signature, Social Security number, address, telephone number, education, employment or employment history.
(iii). Characteristics of protected classifications, such as minority, veteran and disability status, through voluntary self-disclosure. Such information will only be collected as permitted by applicable law and will not be used to make hiring decisions.
(iv). Commercial information, such as records or history of Services and financial or payment information.
(v). Internet or other similar electronic network activity information, such as your IP address, log-in information, browsing history or information regarding your interaction with a website, application or advertisement.
(vi). Geolocation data, such as IP addresses and device location from which we can determine your general location.
(vii). Audio, electronic, visual and similar information, such as call recordings and CCTV footage (such as if you visit one of our offices) created for safety and security purposes, and audio and video recordings of events, conferences and meetings.
(viii). Professional or employment-related information, such as your role/title, employer name, work history, references, information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information and employment termination information.
(ix). Education information subject to the Federal Educational Rights and Privacy Act, such as your education history, education records (such as grades, transcripts and class lists) and other information included in a resume or cover letter.
(x). Sensitive Personal Information, defined under the CPRA to include:
- Social Security or other state identification number;
- account log-in, financial account, debit card or credit card number in combination with any required security or access code, password or credentials allowing access to an account;
- racial or ethnic origin, religious or philosophical beliefs or union membership;
- the contents of your mail, email or text messages (unless Safety Marking is the intended recipient of such communications);
- genetic data;
- biometric data;
- health information; and
- information concerning sex life or sexual orientation (collectively, “Sensitive Personal Information”).
(xi). Legal or contractual information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to, or establish, exercise and defend, legal and contractual rights claims.
(xii). Other information collected in the case of California job applicants, such as job interview notes, responses to screening questions, assessment results and any other information you provide in connection with the recruitment process.
- Section 1: the sources from which we obtain the above categories of personal information;
- Section 2: the business purposes for which we use such categories of personal information; and
- Section 3: the purposes for which we disclose such personal information and the parties to whom such information is disclosed.
B. California Privacy Law Rights
Subject to certain exceptions and limitations, rights under California Privacy Laws include, and you may make, the following requests:
- Right to Know. You have the right to request what personal information we have collected about you in the preceding twelve (12) months (or, if required under the CPRA and to the extent possible, taking into account applicable data retention periods, in the time period starting January 1, 2022), including the categories of personal information collected, the categories of sources from which such information is collected and the business or commercial purpose of collecting such information. In addition, your right to know extends to a right of data portability, which requires us to provide you the pieces of specific personal information that we have collected about you in a portable and, to the extent technically feasible, in a structured, commonly used, machine-readable format so that you may transmit the information to another entity.
- Right to Correct:You have the right to request that we correct inaccuracies in your personal information.
- Right to Delete. Subject to certain exceptions detailed below, you have the right to request that we delete or de-identify the personal information we have collected from you. However, such right does not apply when the information is necessary for us or an applicable third party to do any of the following:
- Provide Services to you.
- Perform a contract between you and Safety Marking.
- Protect your security and enforce your rights regarding the same.
- Protect your or others’ free speech rights.
- Comply with the California Electronic Communications Privacy Act.
- Engage in public or peer-reviewed scientific, historical or statistical research in the public interests that adheres to all other applicable ethics and privacy laws.
- Comply with a legal obligation.
- Make other lawful uses of the personal information, to the extent such uses are compatible with the purposes or context to which such information was provided.
- Right to Request a Record of Third-Party Direct Marketing Disclosures. Also known as the “Shine the Light” law, this permits California residents to request and obtain from us a list of what personal information we disclosed to third parties for direct marketing purposes in the preceding twelve (12) months and the names and addresses of those third parties. This request may be made no more than one (1) time per calendar year.
If you exercise your applicable California rights, Safety Marking will not discriminate against you. To exercise any such rights, please submit a verifiable consumer request to firstname.lastname@example.org. We will verify your identity and respond to your request, taking into account the type and sensitivity of the personal information subject to your request. To protect you (and to protect against fraudulent requests), we may request additional information to verify your identity, including your name, mailing address and email. You may use an authorized agent to submit a request. However, we may need to request that such agent provide evidence that such agent is indeed authorized by you. Moreover, even if an agent submits a request on your behalf, you may still be required to provide us with information that verifies your identity, as described above.
We strive to respond to each verifiable consumer request within 45 days of receiving such request. If we are unable to meet this timeline, we will inform you in writing.
C. Limitations on the Use and Disclosure of Sensitive Personal Information
Under the CPRA, you have the right to limit the use and disclosure of Sensitive Personal Information where such Sensitive Personal Information is used for the purpose of inferring characteristics about a consumer.
However, please note that we do not use Sensitive Personal Information for the purpose of inferring characteristics about a consumer. We use Sensitive Personal Information only for the purposes of providing Services to you, ensuring security and integrity of our Services, short-term transient use, servicing accounts, providing customer service, verifying customer information, for human resources purposes (if you are an employee or job applicant) and quality control and safety control matters.
We do not “sell” or “share”, as each such term is defined under California Privacy Laws, any personal information of minors under 16 years of age.
E. Automated Decision-Making
We do not use personal information for automated decision-making.
NOTICE TO CALIFORNIA JOB APPLICANTS AND EMPLOYEES
Under California Privacy Laws, we are required to provide the following notice, which applies to California residents who apply for employment with Safety Marking, as well as California residents who are current employees. For purposes of this notice, “employees” also includes “interns” and “contractors.” This notice applies to HR Data (as defined below) provided via the Website, in person, or any other means that we receive HR Data, directly or indirectly, from you.
Note: This notice is supplemental to our California Privacy Addendum. If you provide us with HR Data (as defined below), the rights outlined in Section B below, as well as the disclaimers regarding Sensitive Personal Information, minors and automated decision-making outlined in Sections C, D and E, respectively, also apply to such HR Data.
What personal information do we collect from job applicants and employees?
From what sources do we collect HR Data?
- Voluntarily Provided. We collect HR Data directly from you when you voluntarily provide us information requested during the job application or other recruitment process and interview process. If you become or are currently an employee of Safety Marking, you may also voluntarily provide us with HR Data that is needed to administer your payroll, benefits, insurance and taxes.
- Automatically Collected. We automatically collect HR Data in the form of Internet or other similar electronic network activity information (such as IP address or other device identifiers) when you visit the Website, including any careers page or any online job postings.
- Public Sources. We collect HR Data from publicly available sources such as your social media profiles and prior employer websites.
- Private Sources. For job applicants, we collect HR Data from recruiters, prior employers, professional references, universities and other educational institutions and pre-employment screening providers (e.g., background check providers). For both job applicants and current employees, we collect HR Data from credentialing and licensing organizations, as well as governmental entities.
- Other Sources. You may direct us to other sources of HR Data as part of your job applicant process or as part of managing your employment.
How do we use HR Data?
We use HR Data for the following business purposes:
- To process and manage your job application. We use HR Data to evaluate you and your qualifications. We may collect photographs of you for identification purposes during the application process, and, with your consent, we may record video of your interview.
- To conduct screening and background checks. To the extent permitted under applicable law, we may conduct a background check and/or other employee screening check on you. These checks require HR Data, including some Sensitive Personal Information such as social security numbers.
- To apply for a visa or work permit. In some cases, where you need to obtain a visa or work permit, we use HR Data to assist you in doing so.
- To manage your employment. If you become an employee, we use HR Data (including HR Data provided in the pre-employment stage) to manage your employment, including managing any of your associated compensation, benefits, insurance and taxes and any termination of employment. We also may use HR Data to evaluate your ongoing performance at Safety Marking.
- To comply with legal or regulatory requirements. We keep records of HR Data as required by applicable law. In other cases, we may be required by law or legal order to retain or use HR Data, such as to detect, prevent or investigate security incidents, fraud or other illegal activities, or to protect the rights, property and safety of Safety Marking or others.
- Improve our recruiting process and employment practices. We use HR Data to understand and improve our recruiting process, as well as the practices we have with respect to current employees.
How do we disclose HR Data?
We disclose HR Data for the business purposes described above in this notice, both internally within Safety Marking, as well as externally as follows:
- To service providers. We disclose HR Data to service providers that operate and assist in our recruiting process, including recruiting firms, technology providers, security and fraud consultants, analytics providers, screening and background check providers and other providers of hiring management tools used by Safety Marking. For current employees, we disclose HR Data to service providers that assist us in the management and administration of standard human resources functions such as payroll, benefits, insurance and taxes. We also disclose HR Data to IT service providers as part of administering and maintaining our IT infrastructure, networks and security (including servicing IT support requests generated by Safety Marking or by you).
- To governmental authorities and law enforcement. We disclose HR Data as required under applicable law, including to any required state or federal tax authorities. We also may disclose HR Data if we receive a request to do so by governmental authorities or law enforcement. We also may disclose HR Data if required to do so to detect, prevent or investigate security incidents, fraud or other illegal activities, or to protect the rights, property and safety of Safety Marking or others. This may include enforcing a contract or resolving a dispute.
- Professional Advisors. We disclose HR Data to our professional advisors, including our accountants, legal counsel, consultants and insurance providers.