- Personal Information We Collect
- Information Collected through Access and Use of our Properties
- How we Use and Share Information You Provide and We Collect
- Your Choices
- US-EU Privacy Shield and Consent to Transfer Information to the United States
- Service Providers and Onward Transfer
- Third-party Content and Links
- Data Integrity and Security
- Accessing and Correcting Your Personal Information
- Children’s Privacy
- Enforcement and Dispute Resolution
Effective September 26, 2016
For the purposes of this Policy, “personal information” means information that personally identifies a data subject. In addition to other types of information, CommerceHub collects business contact information from users of its Properties, products and services. To the greatest extent permitted by applicable law, business contact information does not constitute personal information.
Please read this Policy carefully. To the greatest extent permitted by applicable law, your use of this Property and/or CommerceHub’s services and technology indicates your consent to this Policy and to CommerceHub’s use, collection, transmission and processing of data and information you or others provide to CommerceHub, in each case, in the manner described herein. If you disagree with the way we collect and process information, do not use this Property.
Personal Information We Collect
Order Data. Our retailer and merchant clients and their suppliers, and the marketplaces, carriers, marketing channels, and other third-party providers with whom they work (each, a “Participant”) use our services to establish connections for the exchange and analysis of information relating to their e-commerce operations and transactions. Participants provide us with information regarding orders transmitted to or received from or for their customers and trading partners, including sufficient personal information to ship orders to customers (“Order Data”). We organize that Order Data and transmit it to other Participants so they can fulfill or process those orders (including returns and order cancellations). Examples of the type of personal information in an Order Data record include, but are not limited to, a consumer’s name, e-mail address, physical address, phone number and items ordered.
CommerceHub acts as a service provider to Participants, and is neither the seller of record, merchant of record, nor fulfiller of products sold to consumers. CommerceHub does not process consumer payments or handle any consumer payment account information, nor is it subject to PCI rules.
Information Provided by You. We collect personal information provided to us by visitors to and users of our Properties, including but not limited to through the use of our client portals; through requests to receive information from us; by completing a registration through a Property such as for a webinar; through comments on our blogs; and through contact with customer service. Examples of the type of personal information we collect include but are not limited to name, e-mail address, company address, and phone number. You are responsible for ensuring the accuracy of all personal information you provide to us. We use third-party tools to collect information from current and prospective users of our services, which may include personal information, but primarily consists of business contact information.
Information from Third-party Services. We use third-party services to update or supplement personal information in our systems, such as to validate or update address information. We may also receive information from our service providers engaged to collect and/or process information on our behalf; for more information, see the “Service Providers and Onward Transfer” section below.
Information Collected Through Access and Use of Our Properties
Web Browser or Device Information. We and our service providers collect information sent by your web browser or device, including your IP address, geolocation, browser and operating system type, domain names, access times and referring website addresses. The information received depends on the settings on your web browser or device. Please review the settings of your web browser or device if you want to learn and change what information is sent by your browser or device. If you access a Property through a mobile device or application, certain of your information may be shared with the mobile carrier or application provider.
“Do Not Track” Headers. “Do Not Track” (DNT) is a web browser setting which lets the websites you visit know that you do not want them collecting information about you. We do not respond to DNT settings or signals.
Analytics Providers. We may use analytics information collected through third-party services, such as Google Analytics, to better understand the manner in which Participants and their users access and use our Properties, including without limitation for reporting, maintenance and development/enhancement purposes. You can manage how Google Analytics collects information about you as described in the “Your Choices” section of this Policy.
Cookies. We may place one or more cookies or other similar tracking technology on your computer. A cookie is a small text file placed on your computer’s hard drive by a web server. Some cookies are used to assist you with your session on our Property. Depending on the cookie, the cookie may expire at the end of your browser session or may stay (or “persist”) on your computer until the expiration date specified in the cookie. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies can only be accessed or read by the Internet domain (generally a web site) that placed them. You have the ability to accept or decline cookies as further described in the “Your Choices” section below. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use certain features of our Property that depend on your web browser accepting cookies.
Embedded Scripts. We use embedded scripts, which is programming code designed to collect information about how visitors interact with a Property, such as identifying the website that referred and linked the visitor to a Property and the manner in which they use a Property. Embedded scripts are downloaded onto your device’s cache from our web server or a third-party service provider and are deactivated or deleted following the end of your session once your browser cache is cleared.
How we Use and Share Information You Provide and We Collect
To Provide Our Services and Related Information. CommerceHub uses information collected through our Properties and services for purposes such as the following:
- to operate and provide users with access to our Properties and services;
- to personalize and support your use of a Property, our products and services, and/or the products and services of our Participants and partners;
- to provide you with information on our products and services (note that, when you provide us with your contact information, you expressly consent to our communicating with you about our products or services);
- to measure and improve our Properties, products and services;
- to refer you to a business partner that provides services in which you have expressed an interest on behalf of your company, or which we believe may benefit your business
- to develop, use, publish and otherwise commercialize Anonymous Information as defined and described below; and
- for any other lawful purposes as disclosed to you at the time you provide your information, with your consent, and as disclosed to you in this Policy.
We do not sell, rent or lease personal information (other than as part of Anonymous Information, as defined below) provided by website visitors to third parties.
To Process Order Data. We receive Order Data from Participants on our network, organize that Order Data and transmit it to other Participants so they can process and/or fulfill those orders. We do not disclose or transmit Order Data (other than as part of Anonymous Information) to third parties other than our service providers (as described below), the Participants associated with that order, or as necessary to provide our services or to comply with legal requirements or to protect you, CommerceHub or others (as described below).
As Anonymous Information. We use non-personally identifiable information collected by or provided to us, and Anonymized Data as defined below (collectively, “Anonymous Information”) for purposes such as the following:
- to personalize and support your use of a Property, our products and services, and/or the services of our Participants and partners;
- to improve a Property, the user experience, and our products and services;
- for security and fraud prevention purposes, such as device fingerprinting;
- to identify actions or transactions as originating through a particular retailer, marketplace, or other channel
- to market, sell, commercialize or otherwise provide reporting, statistics, and insights to our current and prospective Participants, partners and service providers; and
- for other statistical, development, or research and analysis purposes.
In addition, we use personal information (including Order Data) to generate anonymous data, by either (a) using it to generate anonymous transaction and performance data, or (b) “de-identifying” it to remove any information that identifies a person specifically, and use the resulting anonymous data and information (“Anonymized Data”) for the purposes set forth above.
To Comply with Legal Requirements and Protect You, CommerceHub and Others. To the extent permitted by applicable law, we may disclose information when we, in good faith, believe disclosure is appropriate to comply with local or national security, law enforcement, or regulatory processes, requirements or orders; to cooperate formally or informally with law enforcement or other governmental investigations; to prevent or investigate a possible crime, such as fraud or identity theft; to enforce a contract; to protect the legal rights, property, or safety of CommerceHub, its corporate affiliates, and their respective employees, clients, partners and agents, other users or the public in general; to protect the security of CommerceHub’s systems, and the data and information we process or control; or to protect your vital interests if determined necessary by us. In addition, from time to time we may review our server logs for security purposes, such as detecting intrusions into our network. If we suspect criminal activity, we may share our server logs – which may contain visitors’ IP addresses – with the appropriate investigative authorities who use that information to trace and identify individuals. We also reserve the right, without notice, to report to appropriate law enforcement or government agencies any activities that we, in good faith, believe are in violation of applicable laws, rules or regulations.
In Connection with Corporate Events. If one of our corporate affiliates or a third party has acquired all or part of our business, specific assets or the business of one of our operating divisions through which you have provided information to us, e.g., as the result of a sale, merger, reorganization, insolvency, dissolution, liquidation or distribution, ownership of our records and data (including your personal information within them) will be transferred to that successor company. In that event, the acquiring company’s use of your personal information will still be governed by this Policy and any privacy preferences you have expressed to us.
- Information on our Products and Services. If you decide you no longer want to receive marketing information from us on our products and services, such as marketing materials or promotional e-mails, click the “unsubscribe” link in the electronic marketing message you received. Alternatively, you can e-mail us at email@example.com and specify in your e-mail which materials or communications you would no longer like to receive. These communications choices do not apply to mandatory service communications that are considered part of our services, which a user receives periodically until he/she is no longer an active user of our services.
- Google Analytics. You can install Google Analytics’ opt-out browser add-on by visiting http://tools.google.com/dlpage/gaoptout. You can opt out of receiving interest-based Google advertisements, or customize the ads you receive from Google, by visiting http://www.google.com/settings/ads.
- Cookies. If you accept a cookie, you can delete it at any time (e.g., as soon as you leave our Property) through your web browser. If you do not wish to receive cookies or wish to manage when you accept cookies in general, you can set your browser to reject cookies or to alert you when a cookie is placed on your computer. Your use of the features and functionality of this Property will be limited if you set your browser to reject cookies
If you are a consumer whose Order Data is processed through CommerceHub’s services, please contact the Participant to which you originally provided your personal information for information on your choices regarding Order Data.
US-EU Privacy Shield and Consent to Transfer Information to the United States
The Federal Trade Commission (FTC) has jurisdiction over CommerceHub’s compliance with the Privacy Shield.
CommerceHub’s servers are located in the United States and we may also locate servers in the United Kingdom or the European Union. If you are located anywhere outside of the United States, please be aware that information we collect, including personal information, may be transferred to, processed in, and stored in the United States. If you are located outside of the United States, be aware that data protection laws in the United States may differ from those of the country in which you are located, and your personal information can be subject to access requests from governments, courts, or law enforcement in the United States in accordance with and subject to the laws of the United States. By using a Property or providing us with any information, you consent to the transfer, processing, and storage of your information in the United States. You are also consenting to the application of United States federal and New York state law in all matters concerning the Property and this Policy.
Service Providers and Onward Transfer
We use third-party service providers to perform and provide certain services in connection with our business, such as but not limited to verifying and validating information, hosting all or part of Properties, providing usage analytics, sending communications, customer support, log storage, providing marketing assistance and data analysis, and providing other administrative services. We provide service providers access to information only for the purpose of carrying out services on our behalf. Information provided through a portion of a Property that is hosted by a CommerceHub service provider may be stored on the systems of our service provider and processed by that service provider in accordance with our agreement with that services provider.
We may provide personal information to service providers that act as our agent, consultant, or contractor to perform tasks on behalf of and under our instructions. For example, we may store personal information in the facilities operated by a service provider or use a third-party provider to perform data analysis. Such service providers must agree to use such personal information only for the purposes for which they have been engaged by CommerceHub, and they must either:
- comply with the Privacy Shield principles or another mechanism permitted by the applicable EU data protection law(s) for transfers and processing of Personal Data, or
- agree to provide adequate protections for the personal information that are no less protective than those set out in this Policy.
Under the US-EU Privacy Shield, CommerceHub is liable for its onward transfer of personal information to its service providers.
Third-party Content and Links
Data Integrity and Security
We take reasonable steps to ensure that we collect only personal information that is relevant to our provision of our services, and we process your personal information in a manner that is compatible with the purposes for which it was collected or provided to us. To the extent necessary for those purposes, we take reasonable steps to ensure your personal information is usable for its intended purpose and remains accurate, complete and current.
We keep personal information for the purposes for which it was originally collected (or to which you have subsequently consented) and for other legitimate purposes (such as regulatory compliance), as permitted or required by applicable law.
We have implemented reasonable and appropriate safeguards, security technologies and procedures designed to protect personal information from unauthorized loss, misuse, and unauthorized access, disclosure, alteration and destruction. It is important that you understand, however, that no website, application, database or system is completely secure or “hacker proof.”
Accessing and Correcting Your Personal Information
If you provided personal information through one of our Properties, or your personal information has been sent through our services as Order Data, you may access and correct your personal information by sending us a request that identifies the Property you visited or website through which you purchased a product, and other relevant information deemed necessary to retrieve the information. We will work with you to facilitate this review. If you contact us with a request for access to your personal information we will endeavor to respond within 30 calendar days. Your request should be sent by email to firstname.lastname@example.org or by postal mail to Commerce Technologies, LLC, Attn: Legal – Privacy, ZEN Building, 6th Floor, 201 Fuller Road, Albany, NY 12203, United States of America. We reserve the right, however, to limit or deny your request to the extent permitted by applicable law if the disclosure could lead to a breach of applicable law and regulation, such as in case of any legal obligation to retain certain data, or if you have failed to provide the necessary details act on your request or have failed to verify your identity to our satisfaction.
We do not and have no intention of collecting personal information from children under 13. For more information about privacy and the Internet, please visit the Federal Trade Commission’s website at http://www.ftc.gov/bcp.
We expect that this Policy will be updated from time to time to reflect, among other things, changes in applicable laws, rules or regulations, changes in our data collection practices, and/or changes to our business or services. We will make an updated version of this Policy accessible through the Property with a revised effective date, to let you know that we updated the Policy.
If you have any questions about our company or service, please visit our corporate website which includes links to company information, answers to frequently asked questions, and our current policies.
If you have any questions or concerns about this Policy, please contact us.
|By mail:||Commerce Technologies, LLC
ATTN: Privacy Officer
ZEN Building, 6th Floor
201 Fuller Road
Albany, NY 12203
United States of America
Enforcement and Dispute Resolution
In compliance with the Privacy Shield Principles, CommerceHub commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CommerceHub at: email@example.com.
CommerceHub has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under the Privacy Shield Principals, there is the possibility, under certain conditions, for the individual to invoke binding arbitration. Under the US-EU Privacy Shield, CommerceHub is liable for its onward transfer of personal information to its service providers.