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TELUS Agriculture Privacy and Data Use Policy

Updated November 2020

Scope of this Policy

This Privacy Policy (“Policy”) describes TELUS Agriculture Solutions privacy practices with regard to your information. This policy applies to the collection, use, and disclosure of your information by TELUS Agricultural Solutions Inc. (“TAG,” “we,” “us,” and “our”).

In this Policy, we also describe our use of information that we collect in our capacity as a service provider (or data processor) to our customers (see “Information We Collect as a Service Provider”).

Additional Notices & Terms

Depending upon your relationship with us, additional privacy notices may apply. In addition, if you have executed a customer agreement with us, we will use your information, including your personal information, in accordance with the terms of our agreement, and, as permitted by the agreement, and this Policy. If there is a conflict between your customer agreement and this Policy, then your customer agreement will govern.

Disputes

By visiting the Sites, Apps, or using any of our Services, you acknowledge that your personal information will be handled as described in this Policy. Your use of our Sites, Apps, or Services, and any dispute over privacy, is subject to this Policy, any applicable terms of use, EULA, or your customer agreement with us, including any applicable limitations on damages and the resolution of disputes. Where consent is required to process, share, or use your personal information, we will first obtain your consent in accordance with applicable law.

The Information We Collect About You

We collect information about you directly from you, from other sources, and automatically through your use of our Sites, Apps, or Services.

Information We Collect Directly From You

The information we collect from you depends on how you use our Sites, Apps, or Services. Please note not features vary among our Sites, Apps, and Services, and not all features may be available at all Sites (e.g., you may not be able to create an account on all of our Sites).

  • Create an Account to Use Our Services. Some of our Services require you to create an account or register as a user. To create an account, we will collect your name, email address, phone number, and, for some Sites and Apps, farm name and address, and password. If your farm or employer has an offline account with us, we also may request your license or contract number, and we will assign account credentials to you, as directed by you or your employer.

  • Purchase Services. You may make a purchase through certain of our Sites and Apps; if you do so, we will collect contact information, billing and shipping information, payment information, and information about the products and services you acquire or are interested in.

  • Customer Service. You may submit a customer service request through our Sites, Apps, or Services, or by otherwise contacting us. When submitting a service request, we will collect your name, contact information, company information, contact preferences, and information about your service issue or inquiry.

  • Subscribing to Communications. You may sign up for a newsletter and other promotional communications from us by providing your name, country, contact information and subscription preferences to us through our Sites or Apps.

  • Contacting Us/Request for Information. If you contact us for information about us or our Services, we will collect information such as your name, job title, email address, phone number, postal address,  company information (such as business name, farm name, website information), your industry sector, your communication preferences, your reason for contacting us, and the contents of your communication to us. If you do not provide this information to us, we may be unable to respond to your inquiry or provide you with the information you request.

Information We Collect from Other Sources

We also may collect information about you from other organizations and sources.

  • Farm and Business Customers/Your Employer. Our farm and business customers may provide us with information about their employees, contractors, agents, or other persons who need to access the Services. This information may include names, email addresses, contact information and other information necessary to provision access to the Services for such persons.

  • Business Databases and Records. We may license or otherwise obtain information from publicly available databases and social networks to assist us in marketing TAG and our Services. While the information we obtain from these sources is generally focused on legal entities, the information may include names, job titles, and business contact information for these entities’ employees.

  • Data Analytics Providers and Internet Service Providers. We collect data automatically (as described below) through our data analytics service providers and internet service providers.

Information We Collect Automatically

We automatically collect information about your use of our Sites, Apps, and Services through cookies, web beacons, scripts, and other technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information about our use of these technologies. The information we automatically collect includes:

Sites:

  • Domain name;

  • Your browser type and operating system;

  • Web pages you view on the Sites; links you click on the Sites; your device’s IP address;

  • The length of time you visit our Sites and or use our Services available through the Sites;

  • The referring URL, or the webpage that led you to our Sites; and

  • Your device’s location information. With your permission, we may collect your device’s location information to: (1) enable certain features within the Service, such as to identify and map field locations, to track soil samples, and to identify field scout locations; and (2) to help us market TAG and our Services.

Apps:

  • Mobile device identifiers, including device advertising identifiers; device name and model; device IP address; device operating system type, name, and version;

  • Language preference;

  • Activities within the Apps; and the length of time that you are logged into our Apps;

  • Location information. With your permission, we may collect your mobile device’s location information to: (1) enable certain features within the Service, such as to identify and map field locations, to track soil samples, and to identify field scout locations; and (2) to help us market TAG and our Services;

  • Camera and photos. With your permission, the Apps may access your device’s cameras or photos stored on your mobile device for use within the Services, such as for your field scouting purposes.

How We Use Your Information

We use your information, including your personal information, for the following purposes:

Service Provisioning/Transactional Purposes: 

  • To provide our Sites, Apps, and Services to you.

  • To communicate with you about your use of our Sites, Apps, and Services; to fulfill your orders, to respond to your inquiries, and for other customer service purposes.

  • To tailor the content and information that we may send or display to you, to provide access to content and applications you or your organization has purchased or licensed from us, to provide personalized help and instructions, and to otherwise personalize your experiences while visiting the Site or using the Services.

Marketing Communications:

In accordance with applicable laws, we may use your information:

  • To send you marketing communications about our products and services.

  • To send you news, newsletters, and event information.

  • To send you marketing communications about products and services of our affiliated entities.

  • To send you marketing communications about products and services of other entities that we think may be of interest to you. If you are interested in these entities’ products and services, you may provide your information directly to the appropriate entity.

Advertising:

  • To assist us in determining relevant advertising content and media and to create Custom Audiences.

  • To evaluate the success of our advertising campaigns (including our online targeted advertising and offline promotional campaigns).

  • See also the Ad Networks section discussed below.

Site and Product Improvement/Research: 

  • To better understand how users access and use our Sites, Apps, and Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Sites, Apps, and Services are more (or least) used by users, and we will use this information to update or add new features to our Sites, Apps, and Services. We may also use feedback provided by users to update our Services or develop new offerings.

  • To administer surveys and questionnaires, such as for market research or customer satisfaction purposes.

  • To create aggregated, anonymized, pseudonymized or de-identified data sets in accordance with your customer agreement(s). We may use such data sets for research, product improvement and development, marketing, advertising, trend analysis and other purposes.

Legal Purposes:

  • To comply with legal obligations and act in accordance with legal authorizations, as part of our general business operations, and for other business administration purposes, including to comply with our legal and regulatory requirements, authenticating your identity, maintaining customer records, to monitor your compliance with any of your or your organization’s agreements with us, to collect debts owed to us, to safeguard our business interests, and to manage or transfer our assets or liabilities, for example in the case of an acquisition, disposition or ‎‎merger, as described below.

  • Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of  this Policy, your customer agreement, and any applicable terms of use.

  • For other purposes we may inform you about from time to time. Where required by applicable laws and regulations, we will obtain your consent if we wish to use your personal information for purposes requiring such consent.

How We Share Your Information

We may share your information, including personal information, as follows:

  • Service Providers. We disclose the information we collect from you to service providers who perform functions on our behalf. These service providers include hosting services, payment processors and marketing agencies.

  • Affiliates. In accordance with your customer agreement, or where required by applicable law, with your consent, we disclose the information we collect from you to our affiliates, subsidiaries, or other entities in the TELUS family of companies (collectively “TELUS entities”) for the purposes described in this Policy, including the TELUS entities to market their products and services to you, as permitted by applicable law or with your consent. The TELUS entities also may use your information for product analytic, design, and improvement purposes. In some instances, we may transfer your contact information to an affiliate to provide services to you or to contact you about your request for services (e.g., if you contact our Canadian entity and you are based in the United States, we may transfer your data to our U.S. entity to provide services to you).

  • Advertising Networks. We share data with entities that perform targeted advertising on our behalf. Please see the discussion about Ad Networks below.

  • Partner Organizations. We may share non-personal information about your farm or business with our non-affiliated partner organizations. These partner organizations include government and regulatory authorities and our joint marketing partners. 

We also disclose information in the following circumstances:

  • Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, financed or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company.  As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and advisors, including attorneys and consultants.

  • In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, a law enforcement request, or other legal process, such as in response to a subpoena.

  • To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy, your customer agreement, or any applicable terms of use, or as evidence in litigation in which we are involved.

  • Aggregate and De-Identified Information. We share aggregate, anonymized, pseudonymized, or de-identified information about users with other parties for marketing, advertising, research or similar purposes.

Information that We Collect In Our Capacity as a Service Provider

Certain of our products are designed for business customers. We use the information that we collect in our capacity as a service provider for the purposes specified by our customers, which may include service provisioning, product improvement, and customer service, among other uses. We also may disclose this data as required by applicable law.

Location of Service Providers, Hosting and Servers

We and our service providers may be located outside of the country in which you are located, and our and our service providers’ servers ‎‎may be located in Canada, the United States of America, and other countries. You therefore acknowledge that your personal ‎‎information may be processed and stored in foreign jurisdictions and that governments, courts, law ‎‎enforcement or government or regulatory agencies in these countries may be able to ‎‎access or obtain disclosure of your personal information under a lawful order or otherwise through the ‎‎laws of the foreign jurisdiction, irrespective of the safeguards we have put in place for the protection of ‎‎your personal information. If you are located in the European Union or United Kingdom, please see the section below titled Additional Information for Individuals in the European Union and United Kingdom for additional information about cross-border transfers.

Our Use of Cookies and Other Tracking Mechanisms

We, our service providers, and ad networks we work with use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf).

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site or Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.

  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to or users of our Site and Services who disable cookies will be able to browse certain areas of the Site and Services, but some features may not function.

Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device’s hard drive, clear GIFs are embedded invisibly on web and application pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors and Services users, help us manage content, and compile statistics about Site and Services usage. We and our service providers also use clear GIFs in HTML emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Analytics. We use automated devices and applications, such as Adobe Analytics and Google Analytics, to evaluate usage of our Site and Services. We also may use other analytic means to evaluate our Site and Services. We use these tools to help us improve our Sites’ and Services’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn about your Adobe Analytics privacy choices, please visit https://www.adobe.com/privacy/opt-out.html. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to limit their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Ad Network section below.

Ad Networks

Our Sites and Apps may use network advertisers to serve advertisements on non-affiliated websites or other media (e.g., social networking platforms). This enables us and these network advertisers to target advertisements to you for products and services in which you might be interested, including our own. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity's specific privacy policy, not this one. We may provide these advertisers with information, including personal information, about you to assist us with our advertising efforts.

We may disclose certain information (such as your email address) to Facebook Custom Audiences (for more information on Facebook Custom Audience go here or to opt-out, go to the Facebook ad preferences page) – so that we can better target ads and content to you and others with similar interests on other websites or media (“Custom Audiences”). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other ad networks display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below.

Site visitors may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. Users in Canada should go to the Digital Advertising Alliance Canada (“DAAC”) AdChoices Page for information about opting out of interest-based advertising and the choices available from DAAC members. If you are in the European Union, you may opt out of certain ad network cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info. Users in Australia may opt out of certain ad networks by going to the Your Online Choices Page for information about opting-out of interest-based advertising and choices available from participating organizations.

Opting out from one or more companies listed on one of the online advertising industry websites above will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising online. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the websites above, your opt out may not be effective. Additional information is available on the industry websites listed above.

Links

Our Sites, Apps, and Services may contain links to non-affiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those non-affiliated websites. We are not responsible for the information practices of such non-affiliated websites.

Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, device, and computer by, among other things, signing off after using a shared device, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

What Choices Do I Have Regarding Promotional Emails?

In accordance with applicable law, we will send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. We will process opt-out requests in accordance with applicable law. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

Children Under 13

Our Sites, Apps, and Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

Contact Us

If you have questions about the privacy aspects of our Sites or Services or would like to make a complaint, please contact us at privacy@telus.com.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

Additional Information for Individuals in Canada

Consent. We will obtain your consent to collect, use or disclose personal information except where we are ‎‎authorized or required by law to do so without consent. For example, we may collect, use or disclose ‎‎personal information without your knowledge or consent where: the information is publicly available, ‎as ‎defined by statute or regulation; we are obtaining legal advice; or we reasonably expect that obtaining ‎‎consent would compromise an investigation or proceeding. Other exceptions may apply.‎

Your consent can be express, implied or given through an authorized representative.‎

Consent may be provided orally, in writing, electronically, through inaction (such as when you do not ‎‎notify us that you do not wish your personal information collected/used/disclosed for various purposes ‎‎after you have received notice of those purposes) or otherwise.‎

You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided ‎that ‎you give us reasonable notice of your withdrawal of consent. If you notify us that you withdraw ‎consent, ‎we will inform you of the likely consequences of that withdrawal, which may include our ‎inability to ‎provide certain services for which that information is necessary.‎

Access to Your Personal Information. Upon written request and authentication of your identity, we will provide you with your personal ‎‎information under our control, information about the ways in which that information is being used and ‎‎a description of the individuals and organizations to whom that information has been disclosed.  We ‎‎will make the information available within 30 days or provide written notice where additional time is ‎‎required to fulfil the request.‎

In some situations we may not be able to provide access to certain personal information.  This may be ‎‎the case where, for example, disclosure would reveal personal information about another individual, the ‎‎personal information is protected by solicitor/client privilege, the information was collected for the ‎‎purpose of an investigation or where disclosure of the information would reveal confidential ‎‎commercial information that, if disclosed, could harm our competitive position.  We may also be ‎‎prevented by law from providing access to certain personal information.  When an access request is ‎‎refused, we will notify you in writing, document the reasons for refusal and outline further steps which ‎‎are available to you.‎

Accuracy. We will make a reasonable effort to ensure that personal information we are using or disclosing is ‎‎accurate and complete.  In most cases, we rely on you to ensure that your information is current, ‎‎complete and accurate.‎

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the ‎‎information as required.  If appropriate, we will send the amended information to third parties to whom ‎‎the information has been disclosed.  When a challenge regarding the accuracy of personal information ‎‎is not resolved to your satisfaction, we will annotate the personal information under its control with a ‎‎note that the correction was requested but not made.‎

Retention. We will keep your personal information for as long as necessary in connection with the ‎purposes ‎identified above or as permitted or required by law You must notify us if you no longer want us to ‎retain your information.‎

We will destroy, erase or make anonymous documents or other records containing personal information ‎‎as soon as it is reasonable to assume that the original purpose is no longer being served by retaining ‎the ‎information and retention is no longer necessary for a legal or business purpose. We will take due ‎care ‎when destroying personal information so as to prevent unauthorized access to the information.‎

Additional Information for Individuals in the European Union and United Kingdom

The personal information we collect about you is controlled by TELUS Agriculture Solutions Inc., which is headquartered at Floor 23 - 510 W Georgia St, Vancouver, British Columbia, V6B 0M3, Canada.

The Legal Bases for Using Your Personal Information. We collect your personal information as a data controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:

  • Our use of your personal information is in our legitimate interest as a commercial organization (for example in order to make improvements to our products and services and to provide you with information you request); you have a right to object to processing as explained in the subsection below entitled Your Legal Rights;

  • Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example, to facilitate your free trial of our Services, where we use your personal information to respond to your customer service requests, to provide our services through our Sites, Apps, or Services); and/or

  • Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority).

  • Our use of your personal information is in accordance with your consent (for example, when you consent to sharing your personal information with another party for their own marketing).

  • Our use is necessary to protect your vital interests.

If you would like to find out more about the legal bases on which we process personal information, please see Appendix A at the end of this section or contact us using the details below.

Above, we explained that we also collect information in our capacity as a service provider (data processor). Please see:  Information We Collect In Our Capacity as a Service Provider for additional information.

Retention of Your Personal Information. We retain your personal information for as long as necessary to provide our services to you, to fulfil the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy.

Your Legal Rights. Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, when we act as a data controller, individuals in the European Union and United Kingdom have certain rights in relation to their 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 may be transferred.

You also have the right to request that we 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.

Right to Restrict the Processing of Your Personal Information. You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) 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 (iv) you have objected to our personal information use where such use is justified on our legitimate interests and we must verify 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:

  • We have your consent; or

  • To establish, exercise or defend legal claims; or

  • To protect the rights of another natural or legal person.

Right to Data Portability. To the extent that we process your information (i) based on your consent or under a contract; and (ii) 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 Obtain a Copy of Personal Information Safeguards Used for Transfers Outside Your Jurisdiction. You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Economic Area or the United Kingdom.

Right to Withdraw Consent. Where you have given consent to any processing, you have the right to withdraw such consent at any time.  We will explain at the time we request consent how it can be withdrawn.

Right to Lodge a Complaint with Your Local Supervisory Authority. You have a right to lodge a complaint with your local supervisory authority (in the UK, the Information Commissioner’s Office) 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 supervisory authority at any time. 

How to Exercise Your Rights. If you would like to exercise any of the rights described above, please send us a request at agriculture@telus.com. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.

We may 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 may 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. As stated above, we generally maintain servers and systems in the United States and Canada hosted by service providers. We also may subcontract the processing of your information to, or otherwise share your personal information with, other parties in the United States, Canada, or countries other than your country of residence. As a result, where the personal information that we collect through or in connection with the Sites, Apps, or Services, or that we otherwise collect, is transferred to and processed in Canada, the United States or anywhere else outside the European Economic Area (EEA) or United Kingdom for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA or United Kingdom, including entering into data transfer agreements using the EU Commission approved Standard Contractual Clauses or other mechanisms that provide an adequate level of protection for your personal information. You may have a right to details of the mechanisms under which your data is transferred outside the EEA or United Kingdom.

Appendix A: Our Legal Bases for Processing Personal Information of European Union Individuals

Types of Personal Information

Payment Data

Processing Purpose(s): To fulfill and pay for your orders.

Our Legal Basis: Performance of a contract between you and us or your employer and us and/or taking steps, at your or your employer’s request, to enter into such a contract, and our legitimate interests, namely our interest in the proper administration of our website and business.

Inquiry Data

Processing Purpose(s): To respond to your customer service requests, inquiries, and comments.

Our Legal Basis: Legitimate interests, namely the proper administration of our Sites, Apps, and Services and business and communications with users.

Contact Information

Processing Purpose(s): To provide you our newsletters (with your request), to send you email marketing (as permitted by applicable law).

Our Legal Basis: Where you are a corporate customer, the legal basis for this processing is our legitimate interests, namely the marketing of relevant products and services to you, as permitted by applicable law. Where you are a direct customer, the legal basis for this processing is consent.

Account Data

Processing Purpose(s): To provide our services to you.

Our Legal Basis: To fulfill our contractual obligations to you or your employer.