Privacy Notice

Fenner Dunlop Americas, LLC Privacy Notice

 

Last Updated: 8/1/2025

This Privacy Notice (“Privacy Notice”) sets forth the policies and practices employed by Fenner Dunlop Americas, LLC (“Fenner Dunlop”) how we collect, use, and disclose any information associated with an identified or identifiable individual (“Personal Information” or “Personal Data”), as well as the rights and choices individuals have regarding such Personal Information. Fenner Dunlop, the owner and operator of https://fennerdunlopamericas.com/ (the “Website”), and all related services (the “Services”) is a Limited Liability Company formed under the laws of the Delaware.

 

What Information Do We Collect?

Information You Voluntarily Submit: We collect Personal Information from you when you voluntarily provide such information, such as when you contact us, register for access to our Website or Services, sign up for alerts or our newsletter, or purchase products or services. Personal Information may include, but is not limited to:

• Identifying Information, such as names, email addresses, or unique identifiers;
• Contact Information such as your address, phone number, or other communication details;
• In some cases: employment status, family status, interests, and preferences.
• Employment-Related Information, such as job titles, department names, job history, or performance metrics;
• Demographic Information, such as age, gender, occupation, or education;
• Your social media accounts/profiles if you contact us through a social media site or if you access your social media profiles through our site;
• Any information you provide in communications with us, such as via social media, e-mail or our customer call center;
• Other data we are required or entitled by applicable law to collect and process for the purpose of authentication or identification, or for the verification of data we collect
• Any content or contributions you post in a public space on the Website, including forum posts, comments, videos, and photos you share;
• Content you share with other users through our messaging tools;
• Transaction information, including purchases, sales, and shipping information (including information for customs clearance, like tax identification numbers); and
• Payment information, including financial information like credit card and/or account numbers, such as when you make a purchase with us and we need your billing information to process the transaction.
• Tax identification data and numbers, including VAT identification numbers and business EINs that you provide when using our payment services.
• Shipping, billing, and other information you provide in connection with the purchase or shipping of an item, as well as information required for customs clearance and relevant shipping information if shipped by us

To help protect user privacy, we only allow limited access to another user’s contact information as necessary to fulfill any transactions made using the Website, including the collection of payments. Such access may include the other user(s)’ name, unique user ID, email address, and other contact information.

We are not responsible for protecting any information that you choose to share with third parties through the Services. We do not have control over how other users who have access to the Services, including areas not open to the general public, will use any content you share publicly or privately. Please exercise discretion when sharing Personal Information with other users.

Information Collected Automatically: When you interact with the Website, we automatically collect the following information about you:

• Device Information. We collect device-specific information such as operating system version, your device type and name of the mobile network that you are using. Our system logs may record certain information about your visits to our Websites, including the web request, Internet Protocol (“IP”) address, device and mobile ad identifiers, browser information, and other such information; we may collect similar information from emails you receive from us that can help us track which emails are opened and which links are clicked by recipients. If you utilize your login information while utilizing a Virtual Private Network connection, we may collect that information as well.
• Location information. Depending on your device permissions, when you access the Website or use our Services, we automatically collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and mobile towers.
• Client and Log data. Technical details, including the Internet Protocol (IP) address of your device, time zone and operating system. We will also store your login information (registration date, date of last password change, date of last successful login), type and version of your browser.
• Usage Information. We collect information about your activity on our Website which includes a date and time stamp of each visit, advertisement banners or content that you clicked, your interaction with such advertisements, clickstream information, duration of your visit and the order in which you visit the content on our Platform. Based on your interactions and usage of the Website, additional information that is generated as part of such usage, such as transaction information, time and location of transactions, amounts bid, requested, or spent, which we may collect as well. We also collect information from any media uploaded or transmitted through our Website or Services, including any embedded metadata and geotagging information.
• Cookies. See Cookies Policy for further information.

Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Platforms. Please note that not all tracking will stop even if you delete cookies.

Information Collected from Other Sources: We may receive information from third parties such as advertising and marketing partners, public databases, and social media platforms (including from people with whom you are friends or otherwise connected). If we do so, this Privacy Notice governs how we use that information, whether such use is independent of or in combination with information you have provided.

Sensitive Personal Information: Unless you choose to provide it, we do not collect sensitive personal information from you while using the Website. If you elect to submit such information to us, it will be subject to this Privacy Notice.

 

How Do We Use Your Personal Information?

Fenner Dunlop may use Personal Information as permitted by law, for the following business purposes:

• To operate and maintain the Services;
• To respond to your comments or inquiries and fulfill your requests;
• To provide you with user support;
• To track and measure Website performance;
• To protect, investigate, and deter against unauthorized or illegal activity;
• To review the effectiveness of our Website marketing and analyze other general demographic trends;
• To enforce the legal terms that govern our business and commercial relationships; and
• To perform quality control of our Website and Services through analytics and market research, and to otherwise determine the effectiveness, and improve the quality, of our Website and Services.
• To create your user account, identify you as a user of the Website, and customize the Website to your account;
• To improve your experience on our Website and with our Services by providing a personalized experience;
• To send you promotional information, such as newsletters and advertisements, including information and advertisements from our affiliates and on behalf of our promotional and strategic partners;
• To send you administrative communications, such as confirmation e-mails, technical notices, policy updates, or security alerts;
• To notify you of new information or services that may be of interest to you, including promotions, campaigns, programs, contests, or sweepstakes;
• To process payment for purchases you make;
• To communicate with you about orders, purchases, returns, services, and accounts;

We may also use Personal Information as we believe to be necessary or appropriate for certain essential purposes, including:

• To comply with law and legal process and protect rights, safety and property;
• To detect, prevent, or investigate security incidents, breaches, or fraud;
• To enforce our Terms of Use or any other applicable terms or policies or,
• For other purposes requested or permitted by our users or other relevant individuals, such as website visitors.

Some jurisdictions require that companies tell you about the legal grounds that allow your data to be used or disclosed. Below are the types of lawful bases that we will rely on to process your Personal Information:

• Legitimate Interest – the interest of conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We balance the potential impact on you (both positive and negative) and your rights, and if the impact on your rights outweighs our legitimate business interests, we do not use or disclose your Personal Information without your consent or are otherwise required or permitted to by law. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@fennerdunlopamericas.com.
• Performance of Contract – processing your Personal Information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation – processing your Personal Information where it is necessary for compliance with a legal or regulatory obligation.
• Consent – you have given express consent to a certain use of your Personal Information.

Disclosure of Personal Information: To the extent permitted by law, your Personal Information may be disclosed with the following categories of third parties:

• Parent Companies and Affiliates – for business-related functions, Personal Information may be shared with a parent company, any subsidiaries, or other companies under a common control (collectively, our “Affiliates”), but only to the extent such information is provided an equal or greater level of protection as provided by this Privacy Notice;
• Business Transfers – in the event we sell or transfer all or a portion of our business assets, Personal Information may be included in a transfer of assets. We will make every effort to ensure that any Personal Information that is transferred is provided a level of protection equal or greater than is provided by this Privacy Notice, but in the event of such a transfer, you are encouraged to contact the recipient with any inquiries concerning their applicable privacy practices.
• Agents, Consultants and Related Third Parties – for business-related functions (such as mailings, database maintenance, and payment processing) but only to the extent such information is needed to perform their designated function;
• When Legally Required – to law enforcement authorities, regulators, courts and tribunals, governmental or public bodies, and other relevant third parties as we believe necessary or appropriate to protect people or property, to protect our services, rights or property, to comply with legal or regulatory requirements and to respond to legal process, law enforcement requests and requests from other public and government authorities.
• Third Party Vendors – to service providers who provide products and services related to the operation and maintenance of the Website and/or the general operation of Fenner Dunlop’s business (each Third Party Vendor’s use of your Personal Information is dictated by their respective Privacy Notice), including the following Third Party Vendor service providers:
  • Tracking – In order to improve the Website and Fenner Dunlop Services, we will sometimes share your anonymized information with analytics providers that help us analyze how people are using our Services. For example, we use common industry-wide analytics software to understand how people use our app so we can improve the Services and increase engagement. We use the following third-party service providers for tracking:

• • • Google Analytics: Privacy Notice
    • HotJar: Privacy Notice

• • Remarketing – Fenner Dunlop uses remarketing tracking cookies and conversion pixels from vendors such as Google and Facebook to present special offers to you for our products and services over the Google Content Network and via various social media networks. This means that you may see an ad for one of our products or services after having visited our Website. Fenner Dunlop also uses custom audiences based on subscriber email addresses and phone numbers, allowing us to present special offers via Facebook and Google. Your Personal Information is only used by remarketers for the purposes described in this section. We use the following third-party service providers for remarketing:
    • LinkedIn Ads (opt out of LinkedIn remarketing here)
    • Google (opt out of Google remarketing here)

• • Email Marketing – Fenner Dunlop uses ZoomInfo and WebSights for email marketing, including the collection of email addresses and operation of Customer Relationship Management.
    • OneSignal’s privacy notice can be found here.
    • You may access ZoomInfo’s Privacy Notice here.

• • Push Notifications – Fenner Dunlop uses OneSignal to deliver important updates and relevant information through push notifications. When users opt-in to receive push notifications, the device ID is collected and shared with OneSignal to enable the delivery of these notifications. Push notification preferences can be managed or unsubscribed from at any time through your device settings.
    • OneSignal’s privacy notice can be found here.

• • Shipping – Fenner Dunlop uses shipping carriers to process and deliver your orders. These carriers are provided only the information necessary for shipment and delivery of your products. Utility Solutions uses the following carriers for shipping:
    • FedEx – Privacy Notice available here.
    • UPS – Privacy Notice available here.
    • DHL – Privacy Notice available here.
    • United States Postal Service – Privacy Notice available here.
• Other Third Parties – to whom you ask us to send your information.
• Other –
  • Online Contact and Support – We offer multiple ways for you to contact Fenner Dunlop including contact forms, emails, and automated chat. If you choose to contact us through a contact form, the information you provide will be stored by the vendor providing the service you use for such contact, and pursuant to that company’s Privacy Notice. We use the vendors listed below for the respective contact service:
    • Website Contact Form – Self-hosted (WordPress)
    • Online Automated Chat – LiveChat (Privacy Notice)

• • CRM – Fenner Dunlop uses ZoomInfo to manage customer interactions and data, and may be enriched or updated by the vendor to ensure accuracy and relevance.
    • You may access ZoomInfo’s Privacy Notice here.

 

Disclosure of Other Information

In addition to collecting Personal Information, we may collect information that does not identify you and is not associated with your Personal Information.  We may also de-identify, anonymize, or aggregate information so it no longer identifies you.

Analysis of Website Performance: We may use such information and pool it with other information to track, for example, the total number of visitors to our Website, the number of visitors to each page of our Website, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Information is available or used in this process.

Customer Research: In order to better serve and understand the needs of our Website’s users, we may conduct research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. Fenner Dunlop may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

 

Your Rights Related to Your Personal Information

We provide several ways for you to exercise certain privacy choices regarding your Personal Information processed by us. We are committed to respecting your privacy rights under all applicable privacy laws. Some privacy laws require that we provide specific information about individual rights to applicable consumers, which we have set forth in Additional Information for Certain Jurisdictions of this Privacy Notice.

Marketing.  You may opt out from receiving marketing-related communications from us on a going-forward basis by contacting us through the information provided in this Privacy Notice or by using the unsubscribe mechanism contained in each email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

Cookies preferences.  To review and update your preferences for most types of cookies (other than those that are necessary) for our Services, click the “Cookie Preferences” link in the footer of the Website.

Access, Amendment and Deletion.  Under applicable privacy laws, you may have the right to request to review, make amendments, have deleted, or otherwise exercise your rights over your Personal Information that we hold, subject to certain legal limitations and requirements. If you are subject to such a privacy law, you may submit a request to us related to your personal information:

• By submitting an email request to us at privacy@fennerdunlopamericas.com

We will process any request in accordance with – and where required by – applicable law with respect to your Personal Information. We will take steps to verify your identity before implementing your request. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Information that you request.

Although our active systems and databases will reflect updates that have been requested and processed, we may retain all Personal Information for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

We may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

For residents of the EEA, UK, or for residents of U.S. states with applicable data privacy laws, please consult Additional Information for Certain Jurisdictions of this notice for additional information.

Changes to this Privacy Notice

We may periodically update this Privacy Notice.  Please reference the “LAST UPDATED” legend at the top of this page to see when this Privacy Notice was last revised.  Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice.

Age Restrictions

Fenner Dunlop does not knowingly collect any Personal Information from children under the age of 13. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Notice by instructing their children never to provide Personal Information on this (or any) Website without parental permission. If a parent or guardian believes that Fenner Dunlop has Personal Information of a child under the age of 13 in its database, please contact us immediately at privacy@fennerdunlopamericas.com and we will use our best efforts to promptly remove such information from our records and unsubscribe them from any marketing lists.

 

Third Party Privacy Practices

Our Services may contain links to third party websites or apps. If you click on one of these links, please note that each one will have its own Privacy Notice. We do not control these websites/apps and are not responsible for those policies. When you leave the Website, we encourage you to read the Privacy Notice of every website you visit.

We are not responsible for the privacy and data security practices of other organizations, such as Facebook, Instagram, Apple, Google, Microsoft, Twitter or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer. Please read their privacy policies and consider customized settings on your browser or through your mobile phone to limit disclosure of certain information, such as location data.

Any Personal Information that you provide through these third-party websites, mobile applications, or social platforms will be subject to the Privacy Notice of the its operator, and not this Privacy Notice.

 

Do Not Track Signals

We do not monitor or follow “Do Not Track” (DNT) signals because there is no standard interpretation or practice for DNT signals. Therefore, we handle all user information consistent with this Privacy Notice.

 

Miscellaneous Terms and Conditions

Other Terms and Policies

This Privacy Notice is to be read in conjunction with this Website’s Terms of Use, Cookie Policy, and any applicable Sales Terms. Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Fenner Dunlop. Please refer to those agreements as needed.

 

Reservation of Rights

Regardless of any other provision in this Privacy Notice, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) protect, in an emergency, the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations in connection with credit risk reduction and fraud protection.

 

Security of Personal Information

We use standard physical, technical and administrative measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your Personal Information. Unfortunately, no system or network can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us at privacy@fennerdunlopamericas.com.

We will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted for legal, auditing, or compliance purposes.

 

Additional Information for Certain Jurisdictions

Residents of certain countries or U.S. states have additional rights under applicable privacy laws, as described in this section.

• If you are a resident of the EEA or the United Kingdom, please review Section A below for additional information about your privacy rights under applicable privacy laws.
• If you are a resident of the United States, for additional information about privacy rights under certain U.S. state privacy laws, please review Section C, or Section B if you are a California resident.

Residents of the European Economic Area or United Kingdom

 

The GDPR, Swiss, and UK data protection laws (where applicable), give data subjects the following rights regarding their personal information:

Right of access: You have the right to know whether or not personal information concerning you is being processed and, if so, to request access to the personal information. You have the right to request the purposes of the processing, the categories of personal information concerned, and the recipients or categories of recipient to whom the personal information has been or will be disclosed. You have the right to obtain a copy of the personal information undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.

Right to rectify and complete personal information: You can request the correction of inaccurate data and the completion of incomplete data. We will inform relevant third parties to whom we have transferred your data about the rectification and completion if required by law.

Right to erasure (right to be forgotten): You have the right to request that we erase personal information in limited circumstances where:

• it is no longer needed for the purposes for which it was collected;
• you have withdrawn your consent (if the data processing was based on consent);
• following a successful right to object;
• it has been processed unlawfully; or
• to comply with a legal obligation to which we are subject.

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 the establishment, exercise, or defense of legal claims.

Right to restriction of processing: You have the right to restrict the processing of your personal information. In this case, the respective data will be marked and only be processed by us for certain purposes. This right can only be exercised, subject to certain limitations, where: (i) the accuracy of your personal information is contested; (ii) the processing is unlawful, but you do not want the personal information erased; (iii) it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise, or defend legal claims; or (iv) you have exercised the right to object, and verification of overriding grounds is pending.

Right to data portability: You have the right to receive a copy of the personal information concerning you that you have provided to us in a structured, commonly used, machine-readable format. You have the right to transmit such data to another entity without hindrance from us, but in each case only where the processing is (a) based on your consent or on the performance of a contract with you, and (b) also carried out by automated means.

Right to object: You have the right to object at any time to any processing of your personal information that is being processed based on our legitimate interests. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

Right to object to our use of your personal information for direct marketing: You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

Right to withdraw consent: If you have given us your consent for processing of your personal information, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issue with us first, although you have a right to contact your supervisory authority at any time.

You may submit your GDPR, UK GDPR, or Swiss Federal Act on Data Protection request to us via:

Email: privacy@fennerdunlopamericas.com

 

Residents of the State of California

 

CCPA Personal Information Use Disclosure

The California Consumer Privacy Act of 2019 (“CCPA”) requires that we disclose certain categories of Personal Information that we collect, the sources of that Personal Information, the purpose of collecting such information and the categories of third parties with whom we share that information.

Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident.  Below we describe the categories of personal information we may collect about California residents (including the categories of personal information that we have collected about California residents in the past 12 months):

• Identifiers: includes direct identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.  
• Customer records: paper and electronic customer records containing personal information, which you provide to us, such as name, digital signature, address, telephone number, email and other contact information, government identifiers, financial and payment information.
• Characteristics of protected classifications: such as disability and health information (e.g., which we may collect in order to, for example, make accommodations available to you at events we host), as well as inferences made about such characteristics based on other types of information we have collected from you or from third parties.
• Commercial information: including records of real property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
• Usage data: internet or other electronic network activity Information including without limitation browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
• Location data: location information about a particular individual or device.
• Employment history: professional or employment-related information, including inferences about such information based on other types of information we have collected from you or from third parties.
• Education information: education history and background, including inferences about such information based on other types of information we have collected from you or from third parties.
• Profiles and inferences: inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
• Sensitive personal information: in limited circumstances, we may collect certain information considered to be sensitive personal information under the CCPA, including Social Security number and tax ID; driver’s license, state identification card, passport number, or other government identifier; financial account number and payment card data; citizenship or immigration status; and geolocation data.

The chart below summarizes the CCPA disclosure requirements and where you can find this information in this Privacy Notice:

Personal Information Category	Sources of Personal Information (Section 3)	Purpose of Collecting Information (Section 4)	Categories of third parties we share information with (Section 5)
A) Identifiers reasonably capable of being associated with a person or household (such as online identifier, email address)	Information you Provide Us; Information we collect from you automatically when you use the Website; Information Collected from Other Sources.	Providing access to and delivering the Service(s); Improving your experience on the Website; Analysis to improve business operations and services; Responding to inquiries or providing technical support; Providing you a safe and secure platform; Legal compliance and other obligations; Managing internal operations, partnerships, and other business relationships.	Corporate Affiliates; Third Party Vendors and Service Providers; Advertisers; Analytics Providers; Law Enforcement Authorities
B) Personal information categories listed in the California Customer records statute (Cal. Civ. Code Section 1798.80(e)) such as name and telephone number	Information you Provide Us; Information Collected from Other Sources.	Providing access to and delivering the Service(s); Analysis to improve business operations and services; Responding to inquiries or providing technical support; Sending promotional and informational communications; Providing you a safe and secure platform; Legal compliance and other obligations.	Corporate Affiliates; Third Party Vendors and Service Providers; Advertisers; Analytics Providers; Law Enforcement Authorities
C) Protected classifications under CA and federal law, including gender, age and citizenship	Information you Provide Us; Information Collected from Other Sources.	Providing access to and delivering the Service(s); Analysis to improve business operations and services; Sending promotional and informational communications; Providing you a safe and secure platform; Legal compliance and other obligations.	Corporate Affiliates; Third Party Vendors and Service Providers; Advertisers; Analytics Providers; Law Enforcement Authorities
D) Commercial Information, including products or services purchased, obtained or considered, or purchasing or consuming histories or tendencies	Information you Provide Us; Information Collected from Other Sources.	Improving your experience on the Website; Analysis to improve business operations and services; Sending promotional and informational communications; Managing internal operations, partnerships, and other business relationships.	Corporate Affiliates; Third Party Vendors and Service Providers; Advertisers; Analytics Providers
E) Biometric Information	We do not collect.	N/A	N/A
F) Internet or network activity and usage information	Information we collect from you automatically when you use the Website; Information Collected from Other Sources.	Providing access to and delivering the Service(s); Improving your experience on the Website; Analysis to improve business operations and services; Responding to inquiries or providing technical support; Providing you a safe and secure platform; Legal compliance and other obligations.	Corporate Affiliates; Third Party Vendors and Service Providers; Advertisers; Analytics Providers; Law Enforcement Authorities
G) Geolocation Data	We do not collect.	N/A	N/A
H) Audio, electronic, visual, thermal, olfactory, or similar information	We do not collect.	N/A	N/A
I) Professional or employment-related information	Information you Provide Us; Information Collected from Other Sources.	Providing access to and delivering the Service(s); Analysis to improve business operations and services; Responding to inquiries or providing technical support; Sending promotional and informational communications; Legal compliance and other obligations.	Corporate Affiliates; Third Party Vendors and Service Providers; Advertisers; Analytics Providers; Law Enforcement Authorities
J) Education Information	Information you Provide Us; Information Collected from Other Sources.	Analysis to improve business operations and services; Sending promotional and informational communications; Legal compliance and other obligations.	Corporate Affiliates; Third Party Vendors and Service Providers; Advertisers; Analytics Providers; Law Enforcement Authorities
K) Inferences about preferences, characteristics, trends, predispositions	Information you Provide Us; Information we collect from you automatically when you use the Website; Information Collected from Other Sources.	Providing access to and delivering the Service(s); Improving your experience on the Website; Analysis to improve business operations and services; Sending promotional and informational communications; Legal compliance and other obligations.	Corporate Affiliates; Third Party Vendors and Service Providers; Advertisers; Analytics Providers; Law Enforcement Authorities

 

In addition, we may disclose any of the categories of personal information we collect about you to other third parties as directed by or consented to by you, or where necessary to fulfill your specific requests.

Sales and sharing. The CCPA defines a “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA): (i) identifiers, usage data, customer records, commercial information and profiles with our affiliates and subsidiary companies (e.g., so that they may improve or enhance their own records and for other purposes); (ii) identifiers, customer records and commercial information (related to property sales and transactions) with partners and third party businesses, who may use or process the information for their own commercial purposes; and (iii) identifiers, usage data and commercial information to ad networks, social media platforms and data analytics providers (e.g., in order to improve and measure our ad and marketing campaigns).

Sources of Personal Information. We may collect personal information from the following sources:

• Directly from the individual;
• Advertising networks;
• Data analytics providers;
• Social networks;
• Government entities;
• Data brokers;
• Affiliate and subsidiary companies; and
• Service providers.

Purposes of Collection, Use, and Disclosure. As described in more detail in Sections I and II, we collect, use, disclose, and otherwise process personal information (including sensitive personal information) for the following business or commercial purposes or as otherwise directed or consented to by you:

• Providing support and related services;
• Analyzing and improving our business;
• Personalizing content and experiences;
• Advertising, marketing, and promotional purposes;
• Securing and protecting our business;
• Defending our legal rights;
• Planning and facilitating business transactions;
• Auditing, reporting, corporate governance, and internal operations; and
• Complying with any legal obligations.

Retention. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice or otherwise disclosed to you at the time of collection unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend, or protect our legal rights.

California law may permit you to request that we:

• Provide you with a list of the categories of Personal Information we have collected or disclosed about you in the last twelve (12) months; the source category of such information; the business or commercial purpose for collecting or selling the information; and the categories of third parties to whom we disclosed the information;
• Provide access to and/or a copy of the Personal Information we have collected about you.
• Delete certain information we have collected about you.
• Do not sell your Personal Information to any third parties.

Certain information is exempt from such requests under applicable law. You also may have the right to receive information about the financial incentives that we offer to you (if any). You also have certain rights under the CCPA not to be subject to certain negative consequences for exercising CCPA rights.

Submitting CCPA Requests.  California residents may exercise their CCPA privacy rights to know/access, delete, correct, and limit use/disclosure of sensitive personal information by submitting a verifiable request to us via:

Email at privacy@fennerdunlopamericas.co

We will respond to verified requests received from California residents as required by law. When you submit a request to know or a request to delete, we will take steps to verify your identity by matching the information provided by you with the information we have in our records.  You must provide all requested information so that we can process and verify your request.  In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.  Authorized agents may initiate a request on behalf of another individual by contacting us via email or phone; authorized agents will be required to provide proof of their authorization, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Requests to Opt Out. Our Website and App respond to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website.  Note that if you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well.  (You can also manage your preferences for targeting and other cookies on our Website through the “Cookie Settings” link in the footer of each Website.)

More information about GPC is available at: https://globalprivacycontrol.org/.  You may also submit a request to opt out of other sharing and sales by submitting a request via:

Email at privacy@fennerdunlopamericas.com

Incentives. We may make available certain programs or offerings that are considered “financial incentives” under the CCPA, and we will provide notice of the material terms of such incentives and obtain consent from individuals before including them in such incentive programs. You can opt out of such programs at any time through the opt-out mechanism provided in the program information.

Rights Under California Shine the Light Law. California residents may request from businesses with whom they have an established business relationship: (1) a list of categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes and (2) the names and addresses of all such third parties. To request the above information please contact us by writing to us under the “Contact Us” section above. We will respond to such requests within 30 days of receipt.

For more information about our privacy practices, contact us as set forth above.

 

Residents of Other U.S. States

Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information, and if so, provide limited information about the nature of the information collected, processed, and disclosed, the business or commercial purpose, and information concerning third parties to whom the information was disclosed;
• Access and delete certain personal information;
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah);
• Data portability;
• Opt-out of personal data processing for:
  • targeted advertising (excluding Iowa);
  • sales; or
  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah); and
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise or appeal a decision regarding a consumer rights request, please contact us at privacy@fennerdunlopamericas.com

Nevada provides its residents with a limited right to opt-out of certain personal information sales. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

 

Residents of Brazil

Under Lei Geral de Proteção de Dados Pessoais (“LGPD”), residents of Brazil have the right to receive confirmation any processing of their Personal Data and be able to request to receive information about the private and public entities with whom Fenner Dunlop, as the controller, shares their Personal Data.

If you are a resident of Brazil, you can assert these rights when you are requesting the right of access. You also have the right to ask for portability of your Personal Information to another service or product supplier; to object to the processing when data is processed unlawfully; and to request anonymization, blocking, and deletion of unnecessary, excessive or unlawfully processed data. Where the processing of your personal information is based on consent, you have the right to withdraw this consent at any time. This does not affect the lawfulness of the processing based on consent before your withdrawal.

You may make your requests under LGPD by submitting a request via:

Email at privacy@fennerdunlopamericas.com

 

Residents of Canada

Canadian privacy laws, including the Federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Personal Information Protection Act, SBC 2003 c 63, in British Columbia, the Personal Information Protection Act, SA 2003 c P-6.5, in Alberta, and the Act Respecting the Protection of Personal Information in the Private Sector, CQLR c P-39-1 (“Quebec Private Sector Act”), in Quebec.  “Personal Data” and “Personal Information” includes “personal information” as defined under those laws.

Fenner Dunlop’s Privacy Officer is the person in charge of personal information, including under the Quebec Private Sector Act.  You may contact them via email at privacy@fennerdunlopamericas.com.  When Fenner Dunlop collects Personal Data belonging to Canadian (including Quebec) residents, it transfers that data to data centers in the United States.  When Fenner Dunlop relies on service providers to process Personal Data as described herein, those service providers may also be located outside of Canada or Quebec.

You have the right to request access or rectification of the Personal Data Fenner Dunlop holds related to you or to withdraw any consent given to the processing of such personal data.  You may exercise those rights by contacting Fenner Dunlop’s Privacy Officer at privacy@fennerdunlopamericas.com.  If Fenner Dunlop is in possession of your Personal Data that was originally collected with your consent by an entity that subsequently provided that data to Fenner Dunlop, please contact that entity for any questions related to that entity’s privacy policies and consent practices.

 

Residents of Mexico

For residents of Mexico, the Federal Law for the Protection of Personal Data Held by Private Parties and its Regulations provide the following rights: Access, Rectification, Cancellation, and Opposition (“ARCO Rights”) with respect to Fenner Dunlop’s handling of your personal information:

• The right to access your personal information and request explanations about how Fenner Dunlop uses it;
• The right to rectify your personal information if you believe it is outdated, incorrect, or incomplete;
• The right to cancel your data if you believe it is not used according to the principles, duties, and obligations set forth in Mexican data protection laws;
• The right to object to Fenner Dunlop’s processing of your data for certain purposes.

Additionally, the law also provides for an individual’s rights, in certain circumstances, to object to the processing of Personal Data, the right to withdraw consent, the right to object to the use of Personal Data for marketing or advertising purposes, and the right to object to the use of automated decision making or profiling.

Information Needed to Process Your Request

To exercise your ARCO Rights, email your request to privacy@fennerdunlopamericas.com, and please include:

• Your identification or legal representation;
• A clear and precise description of the personal information related to the ARCO rights you wish to exercise and the rights you intend to exercise. You may include this in the body of the message or in a signed and scanned document with initials on each page.

Upon receiving your request, Fenner Dunlop will promptly respond with a confirmation of your request, a description of the action taken, and potentially a request for further information. You will then have 15 business days to reply. If there is no reply, Fenner Dunlop will consider the request complete. Please note that Fenner Dunlop may deny the exercise of ARCO Rights as allowed by law; a denial may be partial, in which case Fenner Dunlop will perform access, rectification, cancellation, or objection as applicable.