We have undertaken the steps required to comply with the GDPR, where applicable, regarding the collection, use, and retention of Personal Information transferred from the EEA to the United States, respectively.
Information We Collect
We may collect several types of information from and about users of the Site, including:
Personal Information: We may collect personally identifiable information (“Personal Information”) from you in a variety of ways including, but not limited to, when you use, navigate, and/or complete forms on the Site as well as in connection with other activities, services, features, or resources we make available. Personal Information may include, without limitation, first and last name, email address, username and password, and IP address.
Usage Information: When you use and navigate the Site, we may collect additional information from you that may not, by itself, reasonably identify you as the source (“Usage Information”). Usage Information may include, without limitation, information regarding your computer, the type of internet browser you are using, the location from which you are visiting the Site, the type of computer operating system you are using to access the Site, the domain name of the website from which you linked to the Site, the internet service provider utilized, or the areas of the Site you visited and the actions you performed on the Site. We will take reasonable measures to ensure that the Usage Information we collect is not personally identifiable and may not later be easily used to identify you as otherwise required by applicable law.
Children Under the Age of 13
The Site is not intended for children under 13 years of age. We do not market to and do not knowingly collect any Personal Information from or about a child under the age of 13 without the consent of the child’s parent or legal guardian. If we discover that we have inadvertently collected information from a child under 13 years of age, we will promptly take all reasonable measures to delete such information from our systems.
How We Collect Information
We may also collect Personal Information and Usage Information (collectively, “Your Information”):
Directly From You: We may collect Personal Information from you when you voluntarily provide Personal Information to us by, for example, completing forms on the Site, when you email us, and in connection with other Marmon activities, services, features, or resources.
Through Your Use of the Site: We may record Usage Information that your browser transmits when you visit the Site. We may also collect Usage Information about how you access and interact with the Site through the use of automated tracking technology, such as “cookies” and “web beacons.” A cookie is a small data file that is transferred to a web browser, which enables the Site to remember and customize your subsequent visits. Most internet browsers automatically accept cookies. You can instruct your browser to block the acceptance of cookies or to provide you with a warning prompt before you accept cookies from the Site. Please refer to your internet browser’s instructions to learn more about these functions. If you reject cookies, the functionality of the Site may be limited and you may not be able to participate in several of the Site’s features. Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Site that allow us to gather information about your browsing activities on the Site.
How We Use Your Information
We reserve the right to use Your Information for various general purposes to help enhance your experience. These purposes may include, but are not limited to:
Customer Service and User Communications: We may use Your Information, including Personal Information, to help us respond to your inquiries, questions, requests and support needs more efficiently.
Provision of and/or Support of Products and Services: We may use Your Information for the purposes of providing and supporting our products and services.
Direct Marketing: We may use Your Information to send you promotional materials. You have the option to opt-out of receiving direct marketing.
Business Optimization: We may use Your Information in managing our everyday business needs. We may also use your feedback to improve the Site and our services.
How We Disclose Information
We will not share, sell, or distribute Your Information with any third parties including any of our affiliated companies, officers, directors, shareholders, subsidiaries, agents, or representatives, except as provided in the following circumstances:
Service Providers: Your Information may be shared with third-party service providers that assist us in providing customer support, communicating with customers, and promoting our services, as well as third-party service providers that provide other services to us relating to the Site and/or our services.
Law Enforcement, Safety, and Legal Processes: Your Information may be shared with law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity. We may also share Your Information if required or permitted to do so by law, for fraud protection and credit risk reduction purposes, or in the good-faith belief that such action is necessary to protect and defend the rights, property, or users of the Site. We may further share Your Information to act under urgent circumstances to protect the safety of our employees or a member of the public, or to comply with a judicial proceeding, court order, or legal process.
How to Withdraw Your Consent
At any time, Data Subjects from the EEA may withdraw consent you have provided to us for using, disclosing, or otherwise processing your Personal Information. You may withdraw your consent by communicating your request at the Contact Information provided below.
Please note that your withdrawal of consent to process certain Personal Information about you (1) may limit our ability to deliver services to you and (2) does not affect the lawfulness of our processing activities based on your consent before its withdrawal. Note that even after withdrawing consent, Marmon may use, disclose, or otherwise process your Personal Information if required by law to do so.
EEA Data Subject Rights: Under certain circumstances, Data Subjects from the EEA may have the following rights under the GDPR:
- To access the Personal Information we maintain about you
- To be provided with information about how we process your Personal Information
- To correct your Personal Information
- To have your Personal Information erased
- To object to or restrict how we process your Personal Information
- To request your Personal Information to be transferred to a third-party
To exercise the above rights, please contact us at the information provided below. We will consider and process your request within a reasonable period of time. Please be aware that under certain circumstances, the GDPR may limit your exercise of these rights.
California Resident Rights: California law provides that California residents have a right to request businesses to tell them how their Personal Information has been shared, if at all, with third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at the information provided below.
The Site uses commercially reasonable security measures to protect Your Information. However, no data transmitted over or accessible through the internet can be guaranteed to be 100% secure. As a result, while we attempt to protect Your Information, we cannot ensure or warrant that Your Information will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network.
To the extent permitted under the GDPR or the Standard Contractual Clauses, Marmon reserves the right to process Personal Data in a manner consistent with the purposes for which the information was collected and without the Data Subject’s knowledge.
When required by the GDPR or the Standard Contractual Clauses, Marmon offers Data Subjects the opportunity to opt out of disclosures of Personal Data to a third party or the use of Personal Data for a purpose that is different from the purposes for which it was originally collected or subsequently authorized by the Data Subjects.
KITCO will comply with the GDPR and the Standard Contractual Clauses with respect to disclosures of Sensitive Personal Data, including, when applicable, obtaining the explicit consent (i.e., opt-in consent) of a Data Subject prior to disclosing Sensitive Personal Data to a third party or using Sensitive Personal Data for purposes other than those for which it was originally collected or subsequently authorized by the individual.
Accountability for Onward Transfer
KITCO is potentially accountable and liable in cases of onward transfers of Personal Data to third parties, such as when third parties acting as agents on our behalf process Personal Data in a manner inconsistent with the GDPR and/or the Standard Contractual Clauses. KITCO will ensure that any third party to which we disclose Personal Data provides the same level of privacy protection as is required by the GDPR and the Standard Contractual Clauses and agrees in writing to provide an adequate level of privacy protection.
KITCO may transfer Personal Data to third party agents, or service providers, who perform functions on our behalf. We enter into written agreements with those third party agents and service providers requiring them to provide the same level of protection required by the GDPR and the Standard Contractual Clauses and limit their use of Personal Data to the specified services provided on our behalf.
Under some circumstances, KITCO may be required to disclose Personal Data when necessary to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Data Security and Integrity
KITCO applies administrative, technical, and physical safeguards designed to provide Personal Information in our possession with reasonable protections from loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, we cannot guarantee the security of Personal Information accessible on or transmitted via the internet.
KITCO processes Personal Information in ways compatible with the purpose for which Personal Information was collected, or as otherwise authorized by an individual. To the extent necessary for such purposes, KITCO takes reasonable steps to make sure that Personal Information is accurate, complete, current, and otherwise reliable with respect to its intended use.
Data Subjects have the right to obtain KITCO’s confirmation of whether we maintain Personal Data relating to you. Further, KITCO will provide you access to Personal Data we maintain about you upon your request and within a reasonable time period. If you become aware that Personal Data we maintain about you is inaccurate, or if you would like to update, delete, or review your Personal Data, you may contact KITCO using the contact information provided below.
KITCO may also limit or deny access to Personal Data where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the GDPR and/or the Standard Contractual Clauses. If KITCO determines that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have. In some circumstances, KITCO may charge a reasonable fee, where warranted, for access to Personal Data.
Recourse, Enforcement, and Liability
KITCO commits to resolve complaints about our collection or use of individual Personal Information. Individuals residing in the EEA with inquiries or complaints regarding our privacy practices or this policy should contact Dan Hanrahan, Chief Compliance Officer of Marmon Holdings, Inc., at (312) 845-5312 or firstname.lastname@example.org, or at the Contact Information provided below.
This Site may contain links to other websites. We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on an external website, even if one or more pages of the external website are framed within a page of this Site. Please be aware that we are not responsible for the privacy practices or policies of such other websites.
Accessing and Updating Information
If you ever wish to access Your Information or to have Your Information deleted, updated, changed, or modified, you may do so by contacting us at the information provided below. To cancel your account and have your information returned to you, please also contact us at the information provided below. We will make commercially reasonable efforts to handle requests to update or modify Your Information within thirty (30) days.
If you would like to opt-out of receiving direct marketing communications from us, you may do so by following any instructions included in the communication or by contacting us at the information provided below
How to File a Complaint
Additionally, Data Subjects from the EEA may file a complaint with EU data protection authorities (“DPAs”). A list of DPAs from the European Commission may be found here: http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061.
Marmon Holdings, Inc.
181 West Madison Street, 26th Floor
Chicago, Illinois 60602
We welcome your questions and comments.