COLLECTION OF PERSONAL INFORMATION
The following table provides some examples of the types of personal information that we collect from or about you:
|Categories||Examples of Data and Purpose for Collection|
|A. Individual Identifiers and Demographic Information||Account Registration Information. When you create an Account, we may collect your name, contact information, and other Registration Information. Such information shall be associated with your Account, and you may update such information by editing the information associated with your Account.|
Demographic Information. We may collect personal information from you, such as your age, photo, or location.
Mailing List Information. When you sign up for one of our mailing lists, we may collect your email address or postal address.
Order Placement Information. We may collect your name, billing address, shipping address, email address, and phone number when you place an order.
|B. Sensitive Personal Information||Sensitive Personal Information. We may collect a subset of personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Maritz will collect sensitive personal information with your express consent or as otherwise permitted by applicable law.|
Payment Information. We will collect your credit or debit card number or bank account information to process any transactions or complete any orders that you place with us.
|C. Geolocation Data||Precise Geolocation. When you use one of our Applications or a badge or device provided by Maritz, we may collect your location using GPS, Wi-Fi, cellular technology, radio-frequency identification (RFID), Bluetooth Low Energy (BLE) beacon technology, or other similar location-tracking technologies. Maritz may capture proximity and duration information for providing personalized products and services, demographic analysis, or behavioral analysis. Such information, and any derived information, may be shared with third parties that have a relationship with Maritz.|
|D. Biometric Information||Facial Recognition Technology. Some of our events may offer the opportunity to participate in special features or offerings using facial recognition technology. If you provide consent, we will collect your photograph and/or a biometric facial scan to help track your attendance and interactions at the event. We may also use facial scanning technologies to track audience responses and engagement at some events, but will not use this data to identify you unless you have provided consent.|
|E. Sensory Data||Videos and Audio Recordings. We may collect audio, electronic, visual, thermal, or similar information, such as customer service call recordings, photographs, or event videos.|
|F. Commercial Information||Automotive Program Information. If you engage with our automotive sales support or rewards program Sites, we may also collect certain information about your vehicle purchasing or maintenance history, such as first and last name, address, the vehicle’s VIN and license plate number, the location where you purchased or received maintenance on your vehicle, and vehicle maintenance history.|
Feedback/Support. If you provide us feedback or contact us for support, we will collect your name and email address and possibly other personal information, as well as any other content that you send to us in order to reply.
Partner Promotions. We may collect information that you provide as part of a co-branded or sponsored promotion with another company or sponsor. Such information may be shared with the promotion partner or sponsor.
Preferences. We may collect information about your preferences and interactions with us, such as dietary restrictions, travel preferences, and marketing preferences.
|G. Internet or Network Activity||Device Information. We may collect information from your computer or mobile device such as unique identifying information broadcast from your device or hardware and software specifications. Such device data may include computer or mobile device operating system type and version number, device or machine ID, manufacturer and model, browser type, screen resolution, IP address, internet service provider, and general location information such as city, state, or geographic area.|
|H. Professional or Employment-Related Information||Employee Incentive Program Information. If you participate in one of our employer-sponsored incentive programs, we will collect employment and professional information such as your contact information, date of birth, work anniversary, incentives points, and your points purchase history.|
|I. Inferences Drawn from Personal Information||Inferences. We may infer information about your preferences and activities from your order history and other personal information that we collect about you.|
We may receive the personal information we collect about you from various sources, including:
From You. We will collect the personal information that you provide to us through the Platform or otherwise.
Service Providers We may collect or receive information about you from third parties that we hire to provide services on our behalf.
Business Partners. Maritz receives information from a number of business partners depending on the services we are providing, such as when we organize an event with a partner, engage in a joint marketing campaign, carry out behavior-based advertising or direct marketing with an advertising partner on the Platform, obtain information about you from data licensors or public sources, provide special offers or benefits, or otherwise work with our business partners or fulfillment vendors.
Our Clients. We may receive information about you from our business customers, such as when they provide us personal information of attendees to an event that we host on their behalf or of employees when we help them offer an employee incentive program.
Automatic Collection We may also collect information about you automatically, including through the methods described in the table above. For example, we automatically receive personal information from users when a user visits and navigates to our Platform on any device; installs and uses the Application; receives our emails; or enables location-based features on the Application. We, our service providers, and our advertising partners may also collect personal information about you over time and across different websites, apps, services, and devices.
Referrals. Users may recommend other contacts to join the Platform by providing their contact information or other data. Users may also provide information about other users of the Platform such as reviews of the services or products that he or she received, booking or scheduling information, or reference information. Please do not provide us with someone’s information unless you have their permission to do so.
USE OF PERSONAL INFORMATION
To Provide Our Platform and Offline Offerings We may use your personal information to:
- Improve your experience on the Platform;
- Provide services, products, information, and content to you and/or to our clients, which may include your employer;
- Communicate with you about information that you request;
- Identify you when you access and use the Platform;
- Register, administer, and monitor Accounts;
- Provide you with products and services you request, or that may be of interest to you;
- Streamline your checkout process;
- Respond to your inquiries related to support, employment opportunities, or other requests; and
- Manage and promote internal administrative purposes, as well as to manage our relationship with you.
Research and Development We may use your personal information for research and development purposes, including to customize our Platform, improve the online experience, and analyze and improve the Platform, our product offerings, and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Platform and promote our business.
Direct Marketing We may send you Maritz-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described below.
Compliance, Fraud Prevention, and Safety. We use personal information to maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, business, and other users. For example, we may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements; enforce the terms and conditions that govern the Platform or our offline offerings; and protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber-attacks and identity theft.
As Required by Law. We use personal information to respond to requests from law enforcement and as required by applicable law, court order, legal process, or government investigation.
With Your Consent. In some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when you consent to our collection and use of your geolocation or biometric information or where required by law.
SHARING OF PERSONAL INFORMATION
- Related Companies. We may share your personal information with our corporate subsidiaries and divisions (e.g., affiliates, parent company, sister companies, joint ventures, or other companies under common control).
- Business Transactions. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, with relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Maritz or our related companies (including, in connection with a bankruptcy or similar proceedings).
- Other Disclosures with Your Consent We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy, and we may do so with your consent.
- Professional Advisors. We may share your personal information with our professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
- Public. Some of our Sites or Applications provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information at these locations, that information may be publicly available.
- Business Partner or Client Promotions and Offerings. We may offer events, contests, sweepstakes, promotions, or any other offerings with business partners or our clients, which may be your employer. The personal information that you submit through an event, contest, sweepstakes, promotion, or other offering may be combined and transmitted with the Registration Information related to your Account. Our business partners may collect information directly from you, which may be combined with personal information disclosed by Maritz. This information may be collected through the Platform or during a Maritz Event. If you decide to enter into or participate in an event, contest, sweepstakes, promotion, or other offering that is offered by Maritz, or a third-party partner or client, the information that you provide may be shared with us and with them. Third party partners and clients that use Maritz products and services to collect personal information must agree to abide by the same principles followed by Maritz.
- Service Providers. We may share your personal information with service providers. Among other things, service providers may help us to administer our website, plan or facilitate events or travel, conduct surveys, provide technical support, send marketing, promotions, and communications related to our business, process payments, and for other legitimate purposes permitted by law.
SECURITY OF PERSONAL INFORMATION
Maritz has implemented reasonable and appropriate security measures to help protect the personal information Maritz collects from unauthorized access, disclosure, alteration, and acquisition. Although Maritz attempts to protect the personal information in its possession, no security system is perfect, and Maritz cannot promise that your personal information will remain absolutely secure in all circumstances.
RETENTION OF PERSONAL INFORMATION
Maritz will retain your personal information as needed to fulfill the purposes for which it was collected. Maritz will retain and use your personal information as necessary to comply with Maritz’s business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
INTERNATIONAL DATA TRANSFER
Maritz is headquartered in the United States and has service providers in the United States and other countries, and your personal information may be collected, used, and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.
If you are located in the European Union, European Economic Area, or United Kingdom, please see the section below titled “Notice to European Users” for additional information regarding your personal information.
OTHER SITES AND SERVICES
The Platform may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
All users can make the following choices regarding their personal information:
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties or Maritz’s clients. You can stop receiving promotional emails by submitting a request at the contact in the “COMMUNICATIONS” section below or following the unsubscribe instructions in emails that you receive. Clicking on an unsubscribe link will take you to a webpage where you can complete the opt-out process. Certain programs will provide a contact for support or other means to remove your name from our contact list. If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your Account, to fulfill orders you have made, to ask you to rate a product you purchased or event you attended, or other service-related communications.
Changes to Your Personal Information. We rely on you to update and correct your personal information. Note that we may keep historical information in our backup files as permitted by law. All requests to correct your information must be directed to the contact in the “COMMUNICATIONS” section below.
Online Tracking. We do not currently recognize browser signals of tracking preferences, which may include “Do Not Track” instructions. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of behavior-based advertising from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), the European Interactive Digital Advertising Alliance (for European users – http://www.youronlinechoices.eu/), and the Digital Advertising Alliance (optout.aboutads.info). Users of our Applications may opt-out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. The opt-out preferences described above must be set on each device and/or browser for which you want them to apply. Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Declining to Provide Your Information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
NOTICE TO CALIFORNIA RESIDENTS
The following section applies only to residents of California. It describes how we collect, use, and share personal information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In some cases we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.
Personal Information That We Collect, Use, and Disclose. For a description of the categories of personal information we may have collected about you in the preceding 12 months by reference to the categories specified in the CCPA, please see section above titled “COLLECTION OF PERSONAL INFORMATION.” The chart below describes whether we have shared these categories of personal information for a “business purpose” or “valuable consideration” as those terms are defined under California law. The CCPA also calls this latter category a “sale” of personal information. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you. For more details about these categories of personal information and our purposes for collecting them, please see the section above titled “COLLECTION OF PERSONAL INFORMATION”.
|Categories of Personal Information||Disclosed for a Business Purpose?||Disclosed for Valuable Consideration?|
|A. Individual Identifiers and Demographic Information||Yes||Yes|
|B. Sensitive Personal Information||Yes||No|
|C. Geolocation Data||Yes||No|
|D. Biometric Information||Yes||No|
|E. Sensory Data||Yes||No|
|F. Commercial Information||Yes||Yes|
|G. Internet or Network Activity||Yes||Yes|
|H. Professional or Employment-Related Information||Yes||No|
|I. Inferences Drawn from Personal Information||Yes||Yes|
- The sources from which we collect this personal information in the section above called “COLLECTION OF PERSONAL INFORMATION”;
- The business and commercial purposes for which we collect this information in the section above called “USE OF PERSONAL INFORMATION”; and
- The categories of third parties to whom we disclose this information in the section above called “SHARING OF PERSONAL INFORMATION”.
Your California Privacy Rights. The CCPA provides California residents with the rights listed below:
Access You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months, including:
- The categories of personal information we collected about you.
- The categories of sources of the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
Nondiscrimination You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our products and services.
Please note, these rights are not absolute and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
How to Exercise Your California Privacy Rights
Access and Deletion Rights. To exercise the access and deletion rights described above, please submit a request to us and provide the information we request that is required to verify your request by emailing us at firstname.lastname@example.org; or
Right to Opt-Out of the “Sale” of Personal Information. Under California law, some of the data we share with our clients or business partners may qualify as a “sale” as defined under the CCPA. To exercise your right to opt-out of such “sale”, please mail us at email@example.com or visit the following link: Do Not Sell My Personal Information
When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You may also designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide the requester’s proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
Notice of Disclosure for Direct Marketing. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Maritz are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared and include a list of the third parties with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit your request to the address listed in the section titled “COMMUNICATIONS” below and include the words “Shine the Light Request” in the subject line.
NOTICE TO EUROPEAN USERS
Lawful basis for processing. Maritz is required to inform you of the lawful bases of our processing of your personal information, which are described in the table below. If you have questions about the lawful basis of how we process your personal information, contact us at the address listed in the section titled “COMMUNICATIONS” below.
|Processing Purpose (for more information, see the corresponding descriptions above in the section titled “USE OF PERSONAL INFORMATION”)||Lawful Basis|
|• To Provide Our Platform and Offline Offerings||Processing is necessary for the performance of a contract that we have directly with you. You are subject to a contract with us and we need to use your personal information to provide products and services. In some cases, processing may also constitute out legitimate interests or be based upon your consent.|
|• Research and Development|
• Compliance, Fraud Prevention, and Safety
|Processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent, or we are otherwise required to perform a contract or by law).|
|• Direct Marketing||Processing activities constitute our legitimate interests. In some jurisdictions, processing may instead be based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Platform.|
|• Behavior-Based Advertising|
• With Your Consent
|Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Platform.|
|• As Required by Law||Processing is necessary to comply with our legal obligations.|
Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Correct. Update or correct inaccuracies in your personal information.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our lawful basis as the basis of our processing of your personal information that impacts your rights.
Delete. Delete your personal information.
When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.
If you are a resident of Europe and would like to exercise any of these rights, please submit your request to the address listed in the section titled “COMMUNICATIONS” below. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection authority in your jurisdiction. You can find your data protection regulator here.
Maritz safeguards and enables the global transfer of personal information in a number of ways. For example, if you or your organization is required to enter into a contract or other binding legal act under EU, UK, or Swiss law with your processors, and Maritz is acting as a processor for you, as the controller, you may request that Maritz enter into a Data Processing Addendum with Standard Contractual Clauses. Please contact us at firstname.lastname@example.org for further information about any such transfers or the specific safeguards applied.
Questions, concerns, or complaints should be directed to our privacy agent as follows:
By Email: email@example.com
Attn: Privacy Agent
Maritz Holdings LLC
1375 N. Highway Dr.
Fenton, MO 63099 USA
If Maritz is required to contact you about your personal information we may do so by mail, phone, or email.
Effective as of January 12, 2022