LAST UPDATED: December 19, 2019
1. ABOUT US AND THIS POLICY
Welcome, and thank you for visiting our website or using our services! When you visit our websites or use our services, you provide and entrust us with personal information that can be used to identify you (which we refer to herein as “your information”).
This Policy describes, among other things, what information we collect from you, how we use and disclose your information, and your rights regarding your information. This Policy is applicable to all of our websites and services that link to it.
We update this Policy from time to time. We will indicate the date the last changes were made above. If we determine, in our discretion, changes are significant, we will provide a more detailed notice and may also notify you of such changes via email.
When this Policy mentions “DinaLiving,” “we,” “us,” or “our” it refers to DinaLiving LTD., or any wholly owned subsidiary that is responsible for your information under this Policy.
We hope this Policy answers all of your questions about our treatment and protection of your information, but to the extent you have further questions regarding this Policy, we invite you to email us anytime at email@example.com or otherwise contact us as provided for herein.
2. INFORMATION WE COLLECT
We sell various commerce items on our website for your needs. As such, we collect many different types of information in connection with your use of our websites and services, including the following.
2.1 Information You Provide Us
- Information for use of Our Services. When you create an account or profile in one of our services, or otherwise use certain services, you may provide personal identifiers, such as your first name, last name, email address, date of birth, phone number, picture, login password, job title and function, address or geographical location, and other similar personal information.
- Information for Identity Verification. In connection with (a) creating and maintaining the security of our services, (b) providing background and screening services, (c) enabling us to make and receive payments, and (e) complying with other various regulatory requirements, you may be required to provide us with information that can be used to verify your identity.
- Information for Purposes of Payment Services. To use certain of our payment services, or to make payments to us, you may be required to provide us with financial information, such as your bank account number, online bank account login, and credit card information. We may also capture additional information when you make payments, such as card type, transaction type, and payee information.
- Information Revealed in Our Communities. When you participate in our communities (help centers, blogs, forums, etc.), you may choose to disclose and provide many different types of personal information that can be used to identify you, your location, your job function, and more.
- Information Provided when You Otherwise Interact with Us. You may provide us with personal information when you fill in forms, respond to surveys, participate in promotions or research opportunities, communicate with our customer service teams, or use other features of our services.
2.2 Information Collected When Using Our Websites and Services
- Device Information. When you access our websites or services we collect device information that can be used to identify you or your device. These identifiers may include IP address, hardware and software information, browser type, device event information, crash data, cookie data, and the pages you have viewed or engaged with before or after accessing our websites or services.
- Activity Information. We may collect details about how you use our websites or services, such as content accessed, time viewed, and links clicked.
- Geo-location Information. When you use certain of our services, we may collect information about your precise or approximate location as determined through your IP address, GPS, or nearby devices (Wi-Fi access points, cell towers, etc.).
- Cookies and Similar Technologies. When you visit our websites or services, we use common technology tools to collect and store information, such as cookies, pixel tags, local storage (such as browser web storage or application data caches, databases, and server logs).
2.3 Information Collected from Third Parties
- Background Information. We may receive information about you, such as demographic data and criminal and credit history, from our trusted background screening and fraud prevention partners. We collect this information only in accordance with applicable law and, when required, with your consent.
- Public Information. We may collect information about you from publicly accessible sources, such as information posted about you on the internet, news stories, and information available from governmental entities.
- Marketing Information. We may collect information about you from our trusted marketing partners who provide us with information about potential customers and partners.
Information we receive from third parties is often combined with information we collect ourselves for the purposes set forth in Section 3 of this Policy.
2.4 Anonymous Usage Information. We collect certain information provided by different constituencies (you, your customers, your vendors) that interact with our services on an anonymous and aggregated basis. We use industry best practices and state-of-the-art techniques to anonymize and aggregate data.
2.5 Information of Children. Individuals under the age of 18 are not permitted to use our services and we do not intentionally collect information on individuals under 18 years of age, regardless of their residency. Incidental exposure to this information may be possible if, for example, our customers upload this information to one of our services or it is inadvertently captured by our marketing organization.
3. HOW WE USE YOUR INFORMATION
We do not use or reference your information or Business Data except to provide, improve, develop, and market our services. Some specific examples of how we use your information follow.
3.1 Providing Our Services. Our services perform many functions and provide our customers with many tools. Use of your information and Business Data is essential for these functions. For example, we require the use of your information to validate login credentials, process payments, and conduct checks against databases. We may also use your information to provide customer service. For example, we may send you service or support messages, updates, and account notifications or we may let you know about upcoming changes or improvements to our services. To protect you and comply with our legal obligations, we use your information to detect and prevent fraud, abuse, security incidents, and other harmful activity, resolve disputes, enforce our terms of service and agreements with third parties, and conduct security investigations and risk assessments.
3.2 Improving Our Services. We are constantly improving our services to better serve you. Your information and Business Data is used in connection with such efforts. For example, we may use your information for data analytics and measurement to determine how individuals interact with our services and where we can provide improved or better functionality. We may use your information to assess the capabilities of third party partners. We may also use your information to engage in research either directly with you or with your customers or other business partners.
3.3 Developing New Services. We are always looking for new ways to serve you by offering new products and services. Your information and Business Data helps us identify and build these products and services in various ways. For example, understanding how some of our customers used our site.
3.4. Marketing Our Services. We may also use your information and Business Data to inform you, your users and your clients of available services we offer, to send you marketing, advertising and other information that we think may be of interest to you.
4. WHO WE SHARE YOUR INFORMATION WITH
We do not share your information or Business Data with anyone except as is necessary to provide our services. We do not and will not sell your information or Business Data. Some examples of when and why we share your information or Business Data follow.
4.1 Service Providers. We use a variety of third-party service providers to help us provide our services, and these third parties may require your information or Business Data for such purposes. For example, service providers may help us: (a) verify your identity or authenticate your identification documents, (b) check information against public databases, (c) conduct background checks, fraud prevention, and risk assessment, (d) perform product development, maintenance and debugging, or (e) provide customer service, payments, or insurance services. We have written agreements with all such third parties and they are not permitted to use your information or Business Data for any purpose other than to deliver the relevant services in a professional manner, and consistent with their legal, regulatory and other obligations. For clarity, we do not and will not share any personally identifiable or sensitive business information with third parties for unknown reasons.
4.2 Legal and Regulatory Disclosures. We may disclose your information or Business Data to courts, law enforcement, governmental authorities, tax authorities, or third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (a) to comply with our legal obligations, (b) to comply with a valid legal request or to respond to claims asserted against us, (c) to respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, or (d) to enforce and administer our Terms of Service or other agreements with users. Such disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's interests or for the purposes of keeping our services secure, preventing harm or crime, enforcing or defending legal rights, or facilitating the collection of taxes.
4.3 Sharing With Your Consent. Where you expressly consent or request, we share your information and Business Data when you authorize a third party service or website to access your account with us.
4.4 Sharing between Users. To help facilitate the use of our services among your users, we may need to share certain information with other users that you authorize to access and use your account. For example, account login information and other certain personal information may be visible by all members for purposes of confirming account permissions and users.
4.5 Public Information. Some of our services let you publish information that is visible or available to the public. For example, if you use our website services, you may elect to include certain of your information or Business Data on websites available to the public at large. Similarly, if you use our premium leads product you post your listings, which include your information, to numerous free and paid listings sites.
4.6 Corporate Affiliates. To enable or support us in providing you services, we may share your information and Business Data within our corporate family of companies.
4.7 Business Transfers. If we are involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information and Business Data in connection with such transaction or in contemplation of such transaction.
- To Service Providers: We may employ other companies or individuals to provide certain services to, or on behalf of, us such as fulfilling orders, delivering shipments, sending postal mail or e-mail, analyzing customer lists and data, processing rebates transactions, providing warranty services, or performing marketing or consulting services. These third parties ("Service Providers") may be given access to your Personal Information needed to perform these services, but will not be permitted to use your Personal Information for any other purpose.
- To Credit Card Companies: If you place an order, the Personal Information you provide is transmitted to your credit card company to verify and authorize your purchase.
- To Third Party Marketing Partners: From time to time we might establish a business relationship with other third parties whom we believe are trustworthy. In such cases with your consent we might license, exchange, share and/or cross-reference information, including your name, postal mailing address, telephone number or email address that will enable such third parties to contact you regarding products and services that may be of interest to you.
- To Related Companies: We may share your postal and e-mail address, telephone number(s), customer preferences, and purchase history with other subsidiaries and affiliates of our parent company, Systemax Inc.
- To Shippers: We may share your information, such as your name, telephone number and shipping information, to third party shippers (such as UPS and FEDEX) to deliver your product(s). There also may be instances in which we drop-ship orders directly to you from one of our manufacturers or suppliers. These drop-shippers are given your information, such as your name, email address, postal address, and telephone number, for the sole purpose of fulfilling your order.
We may also disclose your information:
- To fulfill the purpose for which you provide it.
- To comply with any court order, law or legal process, including responding to any government or regulatory request.
- With your consent.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- When Personal Information is disclosed to third-parties, we use contractual clauses to ensure that your privacy is adequately protected.
Third Party Transaction-Level Data: If you visit the Site from a third-party website, the third-party website may be able to access select information from your individual transaction information. In order to track and credit your transaction the third-party website may give you a unique code, cookie or graphic which will uniquely identify you. This will only happen if you link directly from a third party website to the Site. Any transactions made at the Site while such a code is active will be reported back to the third party website. We will only report non-Personal Information to these websites such as the date of the transaction, the product(s) purchased and the amount spent. We will not report any information to these third party websites that will allow them to personally identify you.
Links to Third Party Site: Our Site, sites we operate, and unaffiliated sites, display interest-based advertising and contain certain links to third party websites, such as our vendors’ websites and links to other websites intended to facilitate our customers’ shopping experience, such as Google Translate. We are not responsible or liable for the privacy practices or content found on these websites. We recommend that you check the privacy notice of each website you visit. Links to third party websites are provided solely for your convenience and any submission of data to such websites shall be at your sole risk.
Catalog Requests: When you request a catalog from us, we may share your name and postal address with a third party fulfillment company for the purpose of sending you the requested catalog.
Law Enforcement and Protection of Users: To the extent permitted by law, we will disclose Personal Information to government authorities or third parties pursuant to a legal request, subpoena or other legal process. We may also use or disclose your information as permitted by law to perform charge verifications, report or collect debts owed, fight fraud or protect our rights or property as well as those of our affiliates, customers, or its users. You should be aware that, following disclosure to any third party, your Personal Information may be accessible by others to the extent permitted or required by applicable law.
Aggregate Information: We provide aggregate information to some of our business partners. This information is used in a collective manner and does not identify you individually in any way. We collect and share aggregate information in order to know more about the general profile of our customers so we can improve your shopping experience. We use a tool called "Google Analytics" to collect information about use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites referred them to the Site. We use the information we get from Google Analytics only to improve the Site and the user experience. Google Analytics collects only the IP address assigned to you on the date you visit the Site, but does not collect your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google Analytics plants a permanent cookie on your web browser to identify you as an unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Sensitive data is encrypted and website connections are protected using strong transport layer security. Our websites are hosted in a secure server environment that uses multi-layer perimeter security, including firewalls and other advanced technology to prevent interference or access from outside intruders.
6. COMMUNICATION MATTERS
6.1 Special Offers, Updates and Research. We may occasionally send you information regarding our services, including educational offers and our newsletter. We also may occasionally contact you, your customers or other third parties related to you to inquire how you or such individuals use our services and how we might improve our services. We typically use names, email addresses and telephone numbers to send these communications and make these contacts.
Out of respect for your privacy, if you no longer wish to receive our newsletter and promotional communications, or if you do not wish for us to contact you, your customers or related third parties for our own internal research purposes, you may opt-out by following the instructions included in each newsletter or communication, or by emailing us at firstname.lastname@example.org. Note that there are certain email communications that you cannot opt-out of as a user of our services, as these notices are required for the continued optimal functionality of our services.
7. EXTERNAL LINKS
Our websites and services may contain links to third party websites. These third party websites maintain their own policies regarding the collection and use of your information. We assume no responsibility or liability for the actions of such third parties with respect to their collection or use of your information. We encourage you to read the privacy policies of every website that you visit, including those you may reach through a link on our websites or in our services. We encourage you to be aware when you leave our websites or services and to read the privacy statements of each and every website you visit that collects your information.
8. GDPR Compliance
The Data Controller of the information collected as noted in the 'Information We Collect' section of this policy is DinaLiving LTD. ("Company" or "We" or "DinaLiving"), which is headquartered in Canada at 3131 Collingwood Street, Vancouver BC, Canada.
The Legal Basis for Using Your Personal Information: We collect your information as a Data Controller when we have a legal basis to do so. The following section sets out the legal basis for processing:
- Our use of your Personal Information is necessary to carry out our obligations and enforce our rights arising from any contracts entered into between you and Global Industrial.
- Our use of your Personal Information is in our legitimate interest as a commercial organization, including to improve your experience on the Site; provide you with information, products or services and to communicate with you about information that you request.
- Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; in particular, where we are required to disclose Personal Information to a court, tax authority or regulatory body in the event of an investigation.
- Our use of your Personal Information is in accordance with your consent.
The foregoing applies to the processing activities described in the 'Our Use of Information We Collect' and 'Disclosure of Your Information to Others' sections of this policy. If you would like to find out more about the legal basis on which we process Personal Information, please contact us.
Your Legal Rights: Subject to certain exemptions, and dependent upon the processing activity we are undertaking, European Union individuals have certain rights in relation to Personal Information:
- Right to Access, Correct, and Delete Your Personal Information: You have the right to request access to the Personal Information that we hold about you and: (a) the source of your Personal Information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your Personal Information is transferred. You also have the right to request that we correct any inaccuracies or delete your information. We are not required to comply with your request to erase Personal Information if the processing of your Personal Information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims. Please be aware that if you request that we delete your Personal Information, you will not be able to continue to purchase products from us, as that requires our use of your Personal Information.
- Right to Restrict the Processing of Your Personal Information: You have the right to restrict the use of your Personal Information when (a) you contest the accuracy of the data; (b) the use is unlawful but you do not want us to erase the data; (c) we no longer need the Personal Information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (d) you have objected to our Personal Information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data. We can continue to use your Personal Information following a request for restriction, where: (i) we have your consent; or (ii) to establish, exercise or defend legal claims; or (iii) to protect the rights of another natural or legal person.
- Right to Data Portability: To the extent that we process your information (a) based on your consent or under a contract; and (b) through automated means, you have the right to receive such Personal Information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
- Right to Object to the Processing of Your Personal Information: You can object to any processing of your Personal Information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Right to Lodge a Complaint With Your Local Supervisory Authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your local supervisory authority at any time.
How to Exercise Your Rights: If you would like to exercise any of the rights described above, please send a request to our Data Protection Officer at email@example.com .com. In your message, please indicate the right you would like to exercise and the information to which it relates. We will ask you for additional information to confirm your identity and for security purposes before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will not always be able to fully address your request, for example if it would affect the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Cross-border Transfer of Information: Our servers and systems are maintained in Canada and the United States.
Retention: We will keep your information accurate, complete and up to date. We will retain your data for the period necessary to fulfil the different purposes outlined in the ‘Our Use of Information We Collect’ and ‘Disclosure of Your Information to Others’ sections of this policy, which will generally be for seven years. In particular, where you are a registered user we will keep relevant information for as long as you continue to purchase products from us. Where we are required to do so to meet legal and regulatory requirements, we will retain your data for longer periods of time, but only where permitted to do so, including so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your data or dealings.
9. MISCELLANEOUS ITEMS
9.1 Information We Host on Behalf of Our Users. We host on behalf of our customers and enable our customers to store various types of data. Such data may include personal information that is collected by our customers. We generally do not control or actively monitor how our customers store or use the data they upload to our services. Any requests or questions related to data collected by our customers should be directed to the applicable party.
9.2 Limits On Use of Your Google User Data. Certain of our services can be used to access Google data. Notwithstanding anything else in this Policy, if you provide our services access to the following types of your Google data, our services use of such data will be subject to the following restrictions:
- Our services will only use such access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
- Our services will not use Gmail data for serving advertisements.
- Our services will not allow humans to read your Google data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our service’s internal operations and even then only when the data has been aggregated and anonymized.
10. CONTACT US
If you have any questions regarding your information, or you'd like to correct and/or update any such information, please contact us at info@DinaLiving.com.
If you have any questions or suggestions regarding this Policy, please contact us at firstname.lastname@example.org.