Privacy Statement and Cookies
Last updated January 1, 2020
All Access, Inc. (“Company”, “our”, “us”, or “we”), the "data controller" of the personal information we collect about you pursuant to this Privacy Statement, is committed to protecting your privacy. This Privacy Statement details the steps we take to protect your personal information when you visit any of our websites or applications that contain a link to this Privacy Statement (collectively, our “Sites”) or when you contact us. It describes how we process personal information relating to you, including the types of personal information that we collect, the purposes for which we use it, the types of third parties with which we share it, and any rights you may have with respect to such information. Personal information is information, or a combination of pieces of information, that allow you to be identified.
This Privacy Statement applies only when you visit any of our Sites that link to this Privacy Statement or when you contact us, for example, with a comment, inquiry or customer support request. Personal information collected about you in connection with other Company websites, products, services or mobile applications (including those made available to you by our group companies) may be covered by different privacy statements. It is important that you read this Privacy Statement together with any other privacy statements or other notices we may provide to you on specific occasions when we are collecting or processing your personal information so that you are fully aware of how and why we are using your information.
By using or accessing our Sites or contacting us you agree that we may process your personal information in the manner described in this Privacy Statement. Your use of our Sites and any information you provide through them is subject at all times to this Privacy Statement and the applicable terms and conditions that apply to the Sites.
IMPORTANT NOTICE FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA (EEA): EEA RESIDENTS MAY BE ENTITLED TO OBJECT TO CERTAIN TYPES OF PROCESSING ACTIVITIES INVOLVING YOUR PERSONAL INFORMATION DESCRIBED IN THIS PRIVACY STATEMENT, INCLUDING WHERE WE ARE RELYING ON A LEGITIMATE INTEREST TO PROCESS YOUR PERSONAL INFORMATION OR WHERE WE ARE PROCESSING YOUR PERSONAL INFORMATION FOR DIRECT MARKETING. IN SOME CASES, WE MAY DEMONSTRATE THAT WE HAVE COMPELLING LEGITIMATE GROUNDS TO CONTINUE TO PROCESS YOUR PERSONAL INFORMATION IN WHICH CASE WE ARE NOT OBLIGED TO COMPLY WITH YOUR REQUEST
1. Our collection of information
1. a) Information collected directly from you. When you visit our Sites, we may ask you for personal information to provide a service or carry out a transaction that you have requested. You may also provide personal information to us when you contact us (e.g., with a comment, inquiry or customer support request) or register for an account to use our Sites.
The personal information we collect from you when you use our Sites may include:
When you do not provide requested information, we may not be able to provide you the requested service or complete your transaction.
1. b) Information we collect about you. We collect certain information about your visit to our Sites, including:
For information about the cookies we use on our Sites, please refer to the section entitled “Cookies” below.
1. c) Geo-location information. For certain Sites, with your express consent, we may collect the precise, real-time location (i.e., geo-location) of your mobile device. This information will be used only for purposes of facilitating your use of the Sites. The geo-location of your mobile device may be disclosed to our service providers who may process this information in connection with providing services on our behalf. Once you have consented to the collection of the precise, real-time location of your mobile device, you may adjust this consent by managing your Location Services preferences through the settings of your mobile device.
1. d) Information collected from third parties. In accordance with applicable law, we may collect personal information about you from third parties, such as social media websites/applications, which we may combine with the information we already hold about you in order to help us improve and customize our Sites to your preferences and for other purposes set forth in this Privacy Statement.
2. Our use of information
We may use the personal information collected via our Sites or when you contact us for purposes that include:
Where permitted by law, we may combine the information that we collect via our Sites with other information we hold about you (such as information about your use of our products and services) in order to offer you an improved and consistent customer experience when interacting with us or for other purposes set forth in this Privacy Statement.
3. The legal basis on which we process information
Where required by law, we will ensure there is a legal basis for the processing of your personal information. In most cases the legal basis will be that:
4. Anonymizing information
In accordance with applicable law, we may anonymize your personal information so that it can no longer be used to identify you. Anonymized information is not considered personal information and is therefore not subject to this Privacy Statement. We may collect, use and share anonymized information for any purpose.
5. How long we keep information
The period during which we store your personal information varies depending on the purpose for the processing. For example, we store personal information needed to provide you with products and services, or to facilitate transactions you have requested, for so long as you are a customer of the Company. We store your personal information for marketing purposes until you have opted out of receiving further direct marketing communications in accordance with applicable law. If you submit an employment application via our Sites, we will retain details of your application as set forth in the privacy statement or other notice made available to you in connection with your application or as otherwise required by law. In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this privacy statement, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed.
6. Disclosure of information
We may share your personal information with selected third parties in accordance with applicable law, including as set out below.
7. International transfers
We are a global company. By using or accessing our Sites or contacting us and giving your information to us, you acknowledge and agree that your personal information may be collected in, transferred to and accessed by the Company, our group companies, suppliers, distributors and other business partners and/or agents located in countries outside of your country or residence, including, but not limited to, the United States, Mexico and India, in accordance with applicable law. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country of residence. However, we will take reasonable steps to protect your privacy and to provide a level of protection of personal information that is comparable to that of your country of residence.
Users Located in the European Economic Area (EEA)
Where required, we have put in place appropriate safeguards with our group companies, service providers, contractors, distributors and other business partners and agents to ensure that transfers of personal information outside the EEA are adequately protected. These safeguards typically comprise the EU Standard Contractual Clauses in accordance with Article 46(2) of the EU General Data Protection Regulation. For more information on the appropriate safeguards in place to protect your personal information, please contact us using the details at the end of this Privacy Statement.
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure, including implementation of such security measures as may be required by applicable law. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to the Sites over networks that we do not control, including the Internet and wireless networks.
The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a User ID and password to access the Sites, you are responsible for keeping those log-on credentials confidential and not revealing them to others.
What is a cookie?
Cookies are text files containing small amounts of information which is downloaded to your hard disk or to your browser's memory when you visit one of our Sites. Cookies are useful because they help arrange the content and layout of our Sites and allow us to recognize those computers or other devices that have been to our Sites before. Cookies do many different jobs, such as allowing our Sites to remember your preference settings and helping us to enhance the usability and performance of our Sites and your experience using them.
Our Sites also may contain electronic images known as web beacons – sometimes called single-pixel gifs – that allow us to count the number of users who have visited specific pages. We may include web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon.
Categories of cookies and similar technologies that we use
The type of cookie or similar technology that may be used on our Sites can be put into 1 of 4 categories: Strictly Necessary, Performance, Functionality & Profile and Advertising.
1. Strictly Necessary Cookies
These cookies are essential, as they enable you to move around our Sites and use their features, particularly in connection with information searches and order placement. Without these cookies, services you have asked for cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet. An example of a strictly necessary cookie is a “shopping basket cookie,” which is used to remember the products that you wish to purchase when you add products to your shopping basket or proceed to checkout.
2. Performance Cookies
These cookies collect information about how you use our Sites, for example which pages you go to most often and if you get any error messages from certain pages. These cookies collect information that is used to improve how our Sites work. Without these cookies we cannot learn how our Sites are performing and make relevant improvements that could better your browsing experience. Examples of performance cookies that our Sites use include Google and Adobe Analytics (see further discussion below).
3. Functionality & Profile Cookies
These cookies allow our Sites to store information that you provide such as your site language preferences and to store technical information useful for your interactions with our Sites. For instance, they remember your user ID and elements of your user profile. They also ensure that your experience using the Sites and our marketing efforts are relevant to you. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. These cookies will not be used to track your browsing activity on other websites.
Without these cookies, a website cannot remember choices you have previously made or personalize your browsing experience. For example, we use a cookie to store your language preferences, which allows us to present you with product search results in the correct language, and we use a cookie to store your choice about the appearance of the cookie information banner that we display on our Sites. This cookie will help us remember your choice about the appearance of the cookie information banner when you subsequently visit the same site where you made your choice about the banner and any other Company sites with the same domain or the same top-level domain.
4. Advertising Cookies and Similar Technologies
These cookies or similar technologies may be used to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the times you see an advertisement as well as help to measure the effectiveness of the advertising campaign. These cookies may track your visits to other websites. Without these cookies or other technologies, online advertisements you encounter will be less relevant to you and your interests.
Setting your cookie preference
Our use of web analytics
We use industry standard web analytics to track visits to our sites. These analytics are provided by Google Analytics, Adobe Analytics, Facebook Pixels, Sitecore Analytics and Coveo (“Web Analytics Providers”). The information generated by the cookie about your use of our Sites (including your IP address) will be transmitted to and stored by our Web Analytic Providers on their servers. The Web Analytics Providers will use this information for the purpose of evaluating your use of our Sites, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The Web Analytics Providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf.
You may opt out of Google, Adobe or Facebook web analytics or otherwise control how these technologies are used when you visit our sites, by following the instructions here:
Facebook Privacy Settings Link (you must be logged into your account)
10. Do Not Track
Some web browsers may transmit “do-not-track” signals to the Sites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
11. Your rights
You may have certain rights with respect to personal information about you that is collected through the Sites or when you contact us. If you are a resident of the EEA, the rights described below may apply to you. For other users, the rights that apply to you will depend on the laws of your country of residence. We will facilitate your exercise of the rights that apply to you in accordance with applicable law. For more information about your rights, please contact us using the contact details at the end of this Privacy Statement.
We will respond to any requests from you to exercise your rights within the timeframes required by law. We may charge a fee to facilitate your request where permitted by law. To exercise any of your rights, please contact us using the contact details set out at the end of this Privacy Statement. We may take steps to verify your identity before taking action on a request. If you believe our processing of your personal information does not comply with data protection law, you can make a complaint to the supervisory authority in charge of overseeing compliance with data protection law in your jurisdiction. We would however appreciate the chance to address your concerns, so please feel free to contact us regarding any complaint you may have.
If you have questions about your rights or wish to exercise your rights, you can submit privacy questions via the following link:
12. Children's information
We do not knowingly collect information from children and do not target or direct our Sites to children. The meaning of “children” is subject to the laws and regulations in the jurisdiction in which you are located.
13. Links to other websites
Our Sites may contain links to third-party websites, products and services. We have no liability or responsibility for those websites, products and services, their policies, or their collection or other processing of your personal information. The practices of those third parties with respect to information collected through their websites, products or services is governed by their own privacy policies. We encourage you to learn about the privacy policies of those third parties.
14. Contact us
If you have questions regarding this Privacy Statement or our handling of your personal information, would like to lodge a complaint, or wish to contact our Data Protection Officer, please contact us using the contact information listed below. We will promptly address your concern and strive to reach a satisfactory resolution.
Changes to this Privacy Statement
We may occasionally update this Privacy Statement. When we do, we will revise the "last updated" date at the top and bottom of the Privacy Statement and take such additional steps as may be required by law.
Last updated January 1, 2020