Last Updated: August 28, 2020
Owner and Data Controller
United Gilsonite Laboratories
1396 Jefferson Avenue
Dunmore, Pennsylvania 18509 USA
Owner contact email: email@example.com
Types of Data Collected
The Sites collect the following types of information that directly, indirectly, or in connection with other information allows for the identification of or is reasonably capable of being associated with a natural person (“Personal Data”):
- First name
- Email address
- Geographic location
- Data communicated while using the service
- Usage data, including IP address
Personal Data may be freely provided by you, or, for example in the case of usage data, collected automatically when using the Sites.
Unless specified otherwise, all Personal Data requested by the Sites is mandatory and failure to provide this Personal Data may make it impossible for us to provide our services through the Sites. In cases where the Sites specifically state that certain Personal Data is not mandatory, you are free not to communicate such Personal Data without consequences to the availability or the functioning of the Sites.
If you are uncertain about which provisions of Personal Data are mandatory, please contact UGL.
You are responsible for any third-party Personal Data obtained, published, or shared through the Site and confirm that you have the third party’s consent to provide the Personal Data to us.
How We Process Data
Personal Data is collected and used for the following purposes:
- to allow us to provide the Sites
- to contact you (after making a purchase or for promotional purposes)
- to comply with our legal obligations
- to respond to enforcement requests
- to protect our rights and interests (or those of our Site users or third parties)
- to detect any malicious or fraudulent activity
- to perform Site analytics
Methods of processing
We implement appropriate and reasonable security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of Personal Data. Processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In some cases, Personal Data may be accessible to certain types of persons involved with the operation of the Sites (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed by us.
Legal basis of processing
We may process Personal Data if one of the following applies:
- Users have given their consent for one or more specific purposes;
- The provision of Personal Data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
- The processing is necessary for compliance with a legal obligation to which UGL is subject;
- The processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in UGL;
- The processing is necessary for the purposes of the legitimate interests pursued by UGL or by a third party.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Personal Data is processed at our operating offices in the U.S. and in any other places where the parties involved in the processing are located, which may include jurisdictions outside your place of residence. Depending on your location, data transfers may involve transferring your Personal Data to a country other than your own.
EU users are also entitled to learn about the legal basis of data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard their Personal Data.
If any such transfer takes place, you can find out more by contacting us using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose for which they have been collected. We may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, certain privacy rights may not be able to be enforced after expiration of the retention period.
Sharing and Disclosure of Information
We may share or disclose your information to the following categories of third parties and for the following reasons:
- Third party service providers, agents, or independent contractors who help us maintain our Sites and provide other administrative services to us. We put in place safeguards to ensure that Personal Data is adequately protected, and we permit service providers to process Personal Data solely for the purposes of providing services to us.
- Third parties in the course of any direct or indirect reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
- Law enforcement, government agencies and other related third parties, in order to comply with the law, enforce our policies, or protect our or others’ rights, property, or safety.
The Rights of Users
Users may exercise certain rights regarding their Personal Data, depending on their place of residence.
EU users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Personal Data. Users have the right to object to the processing of their Personal Data if the processing is carried out under a legal basis other than consent. Where Personal Data is processed for a public interest, in the exercise of an official authority vested in UGL, or for the purposes of our legitimate interests, users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.
- Access their Personal Data. Users have the right to learn if Personal Data is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Personal Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Personal Data and ask for it to be updated or corrected.
- Restrict the processing of their Personal Data. Users have the right, under certain circumstances, to restrict the processing of their Personal Data. In this case, we will not process their Personal Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Personal Data.
- Receive their Personal Data and have it transferred to another controller. Users have the right to receive their Personal Data in a structured, commonly used and machine-readable format, and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Any requests to exercise these rights can be directed to us through the contact details provided below. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.
In the past 12 months, we have collected the following categories of Personal Data:
- Identifiers, such as name and email address.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as a name.
- Commercial information, such as a record of products or services purchased, obtained, or considered.
- Internet or other similar network activity, such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation data, such as physical location or movements.
- Inferences drawn from other personal information, such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The CCPA provides the following rights:
- Right to Know: California residents have the right to request information about the categories and specific pieces of Personal Data we have collected, as well as the categories of sources from which such data is collected, the purpose for collecting such data, and the categories of third parties with whom we share such data. California residents also have the right to request information about our sale or disclosure for business purposes of Personal Data to third parties.
- Right to Delete: California residents have the right to request the deletion of Personal Data, subject to certain limitations.
- Right to Opt-Out of the Sale of Personal Information: California residents have the right to opt out of the sale, as that term is defined in the CCPA, of Personal Data to third parties. We do not sell Personal Data to third parties. We do not sell the Personal Data of minors under 16 years of age without affirmative authorization.
- Right to Nondiscrimination: California residents have the right to not be discriminated against for exercising any of these rights.
If you would like to exercise one or more of the above rights, you can contact us using the contact information provided below. We may need you to provide additional information to verify your request, such as providing data elements so that we can confirm they match the information already maintained by us. We will not use this additional information for anything other than handling your request. Please note that you may designate an authorized agent to make a request under the CCPA on your behalf.
Nevada Privacy Rights
We do not sell consumers’ covered information for monetary consideration (as defined in Chapter 603A of the Nevada Revised Statutes). However, if you are a Nevada resident, you have the right to submit a request directing us not to sell your Personal Data. To submit such a request, please contact us using the information provided below.
Additional Information About Data Collection and Processing
We provide you the opportunity to opt-out of marketing communications by clicking the “unsubscribe” link in email communications or by contacting us using the contact information provided below. We will process your request as soon as possible in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed.
Additionally, we may send you information regarding our Sites and services, such as information about changes to our policies and other notices and disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature, rather than promotional.
Third Party Links
Our Sites contain links to other websites. We are not responsible for the privacy practices or content of such other websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly.
How “Do Not Track” requests are handled
The Sites not support “Do Not Track” requests.
Mailing Address: United Gilsonite Laboratories, P.O. Box 70, Scranton, PA 18501