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Panduit Privacy Notice

Effective Date: January 1, 2020; Last Reviewed On: June 1, 2020

 

This Privacy Notice describes how Panduit Corp., its affiliates and subsidiaries (collectively, “Panduit”) as a business-to-business organization appropriately collects, uses, and shares the personal information of users of the Panduit website and mobile applications, direct customers, indirect customers who purchase Panduit products and services through Panduit’s Authorized Distribution channel, including end users, indirect resellers, installers, and other contractors, members of the ONEsm Partner ecosystem, and vendors.  This Privacy Notice does not apply to events sponsored or co-sponsored by Panduit—you will receive an event-specific privacy notice if you register for an event.  This Privacy Notice also explains the options you have to manage your Personal Information.  This Privacy Notice is compatible with audio-readers such as Read Aloud.

We may update this Privacy Notice from time to time. If we do, we’ll let you know about any material changes, either by notifying you here or by sending you an email.

 

Why Personal Information Do We Collect?

We may collect or obtain the following categories of personal information:

  • Contact Information (like your first name, last name, email, social media handle, telephone number, fax number, mailing address, and/or country);
  • Account log-in credentials (username, password);
  • Professional and employment-related information (like your title, industry, profession and employer);
  • Payment Information, including payment card numbers, and bank account information);
  • Records of correspondence;
  • Records of products and services you have purchased, obtained, and considered;
  • Audio recordings when you call customer service;
  •  Visual recordings when you visit a Panduit facility;
  • Geolocation data when you use a Panduit mobile application; and
  • Any other information you provide to us.

 

In addition to the above, we may also collect other information related to user interactions with our website and mobile applications (“Usage Data”).  Much of this Usage Data, such as clickstream data and aggregate usage statistics, do not identify a particular individual. However, some of this Usage Data either alone or when combined or linked with your personal information, may allow your identity to be discovered. In such cases, we treat the combined data as personal information. In many cases, Usage Data are gathered automatically by systems or technology such as cookies.

 

Examples of Usage Data that may be collected by Panduit include:

  • Details about your computers, devices, applications, and networks (including IP address, browser characteristics, device ID, cookie/session ID, authentication information, browser type/version, operating system/platform, and language preferences);
  • Activities on our websites and mobile applications, including your search terms, pages viewed, clicks, downloads, dates and times of visits, and other usage patterns.

 

How Do We Collect Information?

Information That You Give Us: Typically, we obtain information directly from you and you decide how much information to share with us. 

Information Collected Automatically: When you use or interact with our websites and mobile applications, we receive and store Usage Data as described in Section 1 above.  In most cases, this information is generated by various tracking technologies.  While some of these technologies depend on the use of a cookie, visitors to the Panduit website have the option of disabling cookies via their browser preferences.  In the event you visit a Panduit facility, there may be security cameras that capture your image.  In the event you call customer service, that call may be recorded for quality assurance and training purposes. 

Information from Other Sources: Your organization may provide details about you to facilitate your engagement with Panduit or another organization (e.g. the host of an event or webinar) may do so upon your request.  We may also supplement our records of you to ensure we have accurate information about your industry or profession with information provided by consumer data resellers.  We may also receive your Usage Data (as defined in Section 1 above) from data analytics providers.

 

How Do We Use Personal Information?

We may use the personal information we collect for one or more of the following business purposes:

  • Create, maintain, customize, and secure your account with us;
  • Provide our products, services and programs, including our websites and mobile applications, and improve them over time;
  • Process payments and facilitate deliveries;
  • Perform accounting, auditing, billing, reconciliation, and collection activities;
  • Carrying out our obligations and enforcing our rights arising from agreements entered into between you and us;
  • Provide customer support, and respond to requests, questions, and comments, including monitoring and improving our responses;
  • Advertising, marketing, and selling our products and services;
  • Personalize your website and mobile application experience, and deliver Panduit content, product, service, and program offerings relevant to your interests, including targeted offers and ads through our websites, mobile applications, email, text message/SMS, telephone, fax, or mail (with your consent when required by law);
  • Linking together or merging personal information with other personal information so that we may better understand your needs and inform you about our products, services, and programs; 
  • Anonymizing and aggregating information for analytics and reporting purposes; 
  •  Help maintain the safety, security, and integrity of our website, mobile applications, products, services, programs, offerings, databases, and other technology assets, and business;
  • Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred;
  • Comply with and enforce applicable legal requirements;
  • As described to you when collecting your personal information;
  •  For any other purpose with your consent.

 

How Do We Share Personal Information?

We may share the personal information we collect in one of the following ways:

  • Service Providers.  We may disclose personal information to our service providers to perform functions on our behalf consistent with the descriptions set forth in Section 3 above (e.g. website hosting provider, customer relationship management provider) pursuant to written agreements with confidentiality, privacy, and security obligations.
  • Government Entities.  We may disclose personal information as necessary or appropriate under applicable laws to comply with legal processes or requirements; respond to requests from public or government authorities; and protect our operations, rights and safety.

 

Third-Party Advertising

We partner with third parties to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on these sites and other sites in order to provide you Panduit advertising based upon your browsing activities and interests (“retargeting”). If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by emailing privacy@panduit.com.

 

What Choices Do You Have About Your Personal Information?

In addition to the rights discussed in other sections of this notice, you may choose not to receive marketing communications from us by clicking on the unsubscribe link found in our marketing emails, or contacting us as specified in Section 14 “Contact Us” below.

If you choose to no longer receive marketing information, Panduit may still communicate with you regarding such topics as customer service, responses to inquiries, or other transactional, non-marketing related purposes.

If you have created an account with our Distributor Portal or  ONEsm Partner Portal at www.panduit.com, you can log-in to modify or update your information.

 

What Security Measures Do We Use?

Panduit implements physical, administrative, and technical safeguards designed to protect your personal information from unauthorized access, use, or disclosure. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosure.

 

Data Retention and Erasure

Subject to applicable laws and as otherwise stated in Sections 12 and 13 below, your personal information will be retained for as long as Panduit has a legitimate reason to do so and will thereafter be deleted. 

 

Open Forums

If you participate in a discussion forum or chat room on a Panduit website, you should be aware that the information you provide will be made broadly available to others, and could be used to contact you, send you unsolicited messages, or for purposes neither Panduit nor you have control. Panduit is not responsible for the personal information or any other information you choose to submit in these forums.

 

Links to Other Sites

Our websites and mobile applications may contain links to other sites for your convenience and information. These sites may be operated by companies not affiliated with Panduit. Linked sites may have their own privacy policies, which you should review. Panduit is not responsible for the content, privacy practices, or use of any websites that are not affiliated with Panduit.

 

Children’s Data

Our websites and applications are not directed to children under 16, and we do not knowingly collect any personal information directly from children under 16.  If you believe that we are processing the personal information pertaining to a child improperly, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

 

California-Specific Privacy Notice

For California consumers, we collect personal information as defined by the California Consumer Privacy Act (CCPA), which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  Personal information does not include de-identified or aggregate information, publicly-available information that is lawfully made available from federal, state, or local government records, and information covered by certain sector-specific privacy laws.

In the twelve months preceding the date this Privacy Notice was last updated, we have collected the following categories of personal information from the following sources.

  

Personal Information

Source

Identifiers (e.g., name, postal address, online identifier, IP address, email address, account name, driver’s license number, or other similar identifiers)

Directly from you and your organization; another organization with your consent

Categories of personal information described in California Civil Code §1798.80(e) (e.g., signature, telephone number, bank account number, credit card number, debit card number, or other financial information

Directly from you and your organization; another organization with your consent

Commercial information (e.g., records of products or services purchased, obtained, or considered)

Directly from you and your organization

Internet or other electronic network activity information (e.g., pages visited, browsing history, search history, information regarding interaction with the Website

Indirectly from you; data analytics providers

Audio, electronic, visual, thermal, olfactory, or similar information (e.g., audio and visual recordings)

Directly from you via telephone; Indirectly from you via CCTV

Professional or employment-related information (e.g., occupation)

Directly from you and your organization; consumer data resellers

Inferences drawn from other personal information (e.g. a person’s preferences)

Directly from you and your organization; data analytics providers

We use the categories of personal information listed above for the business purposes listed in Section 3, above.  We disclose each category of personal information listed above to our service providers for business purposes.

In the preceding twelve months, we have not sold personal information.  Our policy is that we do not and will not sell your personal information, unless you give us your consent or direct us to do so.

California residents have the right to: (1) request that we disclose what personal information we collect, use, disclose, and sell; (2) request deletion of personal information; (3) opt-out of the sale of personal information; and (4) not receive discriminatory treatment for exercising their rights under the CCPA.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.  To designate an authorized agent that does not have power of attorney, please contact us by email at privacy@panduit.com.  We may require you to verify your identity as well as provide written authorization for the individual to make requests under the CCPA on your behalf.

 

Requests to Know

You have the right to request that we disclose the following information:

  • Specific pieces of personal information Panduit has collected about you;
  • Categories of personal information Panduit has collected about you, disclosed about you for a business purpose, or sold;
  • Categories of sources from which the personal information is collected;
  • Categories of third parties with whom Panduit shares or to whom Panduit sells personal information; and
  • The business or commercial purpose for collecting and selling personal information.

Please see below for further details on making such request.

 

Request to Delete

You have the right to request that we delete personal information about you that we have collected and maintain, subject to certain exceptions.  Please see below for further details on making such request.

 

Exercising Access, Data Portability, and Deletion Rights

To make a request to know and/or delete, please contact us by email at privacy@panduit.com.  Once we verify your request, we will respond appropriately. 

Please note that only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request to know twice within a 12-month period.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

“Shine the Light”

California Civil Code Section § 1798.83 permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.  To make such a request, please contact us at privacy@panduit.com. Please note, however, that Panduit does not disclose personal information to third parties for their direct marketing purposes unless we have previously obtained your consent.

 

European Economic Area (EEA) Specific Rights

For individuals located in the EEA, we collect personal data as defined by the General Data Protection Regulation (“GDPR”), which data are any information which are related to an identified or identifiable natural person.  If you are located in the EEA, you have the right to request access to, rectification, or erasure of your personal data, or restriction of processing or object to processing of your personal data, as well as the right to data portability, in accordance with applicable laws. The following is a summary of what these rights involve:

 

  • The right of access enables you to receive a copy of your personal data.
  • The right to rectification enables you to correct any inaccurate or incomplete  personal data.
  • The right to erasure enables you to ask us to delete your personal data in certain circumstances, for example where it is no longer necessary for us to process it or if you consider it is being unlawfully processed. Your request can be refused if the processing is necessary to comply with an EU or Irish legal obligation or for the exercise or defense of legal claims.
  • The right to restrict processing enables you to ask us to halt the processing of your personal data in certain circumstances, for example if you want us to verify its accuracy or our legitimate interests in processing it.
  • The right to object enables you to object to your personal data being processed on the basis of our legitimate interests (or those of a third party).  We will stop such processing unless there are compelling legitimate grounds for the processing or the processing is necessary for the exercise or defence of legal claims. You also have the right to object to us processing your personal data for direct marketing purposes.
  • The right to data portability enables you to request us to transmit personal data, that you provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party.

 

However, these rights may not be exercised in certain circumstances, such as when the processing of is necessary to comply with a legal obligation or for the exercise or defense of legal claims.  Any requests to exercise your rights should be addressed to privacy@panduit.com.  

We will respond to your request in writing, including by electronic means, within 45 days of receipt of your request.  We may request proof of identification to verify your request.  We have the right to refuse your request in some circumstances.  You have the right to lodge a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your personal data infringes the GDPR.  A list of data protection authorities is available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. Panduit encourages you, however, to use its own internal procedure to resolve any concerns you may have about data privacy.  To exercise this right please contact privacy@panduit.com.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the EEA, for the purposes described above. Those countries may not provide an adequate level of protection under European data protection law for the processing of personal data. Due to the global nature of our business, your personal data may be disclosed to members of our group outside the EEA, including in particular in the USA. It may also be processed by personnel operating outside the EEA who work for us or for one of our suppliers who act on our behalf. We will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data. Please contact us if you wish to obtain information concerning such safeguards (see Section 14 “Contact Us” below).

 

Contact Us

If you have any questions, concerns or requests related to this Privacy Notice, you can contact us:

By email:

privacy@panduit.com

By post:

Panduit Corp.
Attn: Legal Department
18900 Panduit Drive
Tinley Park, IL 60487