Last updated: January 30, 2019
1. What is Personal Information?
As used herein, the term “Personal Information” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, or credit card number), or information about that individual that is directly linked to personally identifiable information. Personal Information does not include “aggregate information”, which is data we collect about the use of the Services or about a group or category of services or users from which individual identities or other personal information has been removed. Personal Information also does not include Usage Information (as defined below) or Device Identifier (as defined below) that is not connected to Personal Information. This Policy in no way restricts or limits our collection and use of aggregate or Usage Information that is not connected to Personal Information.
2. Information Collected on Our Services
INFORMATION YOU PROVIDE TO US
You may choose to provide Personal Information through the Services. For example, the Company may collect Personal Information when you register or create an account, schedule a service appointment, register for a promotional event, submit a finance application, use our digital retailing services, submit information or content (“User Content”) or apply for a job. If you do not want your Personal Information collected, please do not submit it or use these features.
INFORMATION COLLECTED BY AUTOMATED MEANS
Whenever you visit or interact with the Services, the Company, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Services are accessed and used (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time, how many users visited the Services, and the preceding page views. This statistical data provides us with information about the use of the Services, such as how many visitors visit a specific page on the Services, how long they stay on that page, and which hyperlinks, if any, they “click” on. This information helps us to keep the Services fresh and interesting to our visitors and to tailor content to a visitor’s interests. Usage Information is generally non-identifying, but if the Company associates it with you as a specific and identifiable person, the Company treats it as Personal Information. In the course of collecting Usage Information, the Company also may automatically collect your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Services. A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. When you visit the Services, we may view your Device Identifier. We may use this information to determine the general physical location of your Device and understand from what regions of the world the visitors to the Services come. We also may use this information to enhance the Services. The technologies used on the Services to collect Usage Information, including Device Identifiers, may include, without limitation:
Like many companies, we use “cookies” on the Services. Cookies are data files placed on a Device when it is used to visit the Services. The Company, or our third-party advertising service providers, may place cookies or similar files on your Device for security purposes, to tell us whether you have visited the Services before, if you are a new visitor or to otherwise facilitate site navigation, and to personalize your experience while visiting our Services. Cookies allow us to collect technical and navigational information, such as browser type, time spent on our Services and pages visited. Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. Cookies may enhance your online experience by saving your preferences while you are visiting a particular Service. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that if you disable or reject cookies, some features and services on our Services may not work properly because we may not be able to recognize and associate you with your profile. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.
Certain pages on the Services may contain “web beacons” (also known as Internet tags, pixel tags, tracking beacons and clear GIFs). A web beacon is a transparent graphic image placed on a web page or in an email, which indicates that a page or email has been viewed or that an email has been forwarded. In addition, a web beacon allows third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. A web beacon may also tell your browser to get content from another server. In order to ensure the safekeeping of your information, network advertising companies and publishers are not permitted to directly collect Personal Information on our Services.
Do Not Track
Currently the Services are not designed to respond to “Do Not Track” signals sent from your browser. For more information more about “Do Not Track,” please visit www.allaboutdnt.org.
INFORMATION WE RECEIVE FROM THIRD PARTIES
We may receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from the Company, that website will forward to us your e-mail address and other information about you so that we may contact you as requested. You may also choose to participate in a third party applications or features (such as one of our Facebook or Twitter applications or a similar application or feature on a third party website through which you allow us to collect and share (or the third party to collect and share) information about you, including Personal Information. If you access the Services through a third-party connection or log-in, we may also collect your user ID and/or username associated with that third-party service, and any information you have made public in connection with that service or which the third party shares with partner services. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” webpage, profile page, or similar page on a social networking or other third party website or interactive service. The collection and use of this information is pursuant to such third party’s information collection practices, which are typically outlined in a policy like this one, provided on the third party’s website or application.
We also may supplement the information we collect about you through the Services with other information from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you. We may combine the information we receive from these third parties with information we collect through the Services. In those cases, we will apply this Policy to any Personal Information received, unless we have disclosed otherwise.
SOCIAL MEDIA APPLICATIONS
You may also be able to submit User Content to the Services through these social media applications.
3. How We Use the Information Collected
We use Personal Information we collect through the Services for the purposes described in this Policy or elsewhere on the Services. For example, we use Personal Information and other information we collect:
- to provide the services, products, or information you request and to process and complete any transactions in connection therewith;
- to communicate with you and respond to your emails, submissions, questions, inquiries, comments, requests, and complaints and to provide customer service;
- to personalize and improve the Services and users’ experiences, to increase the functionality and user friendliness of the Services, to deliver advertisements, content, or features that match user profiles or interests, and to provide recommendations as to other advertisements, content or features that may be of interest to users;
- to monitor and analyze Services usage and trends and otherwise measure the effectiveness of the Services;
- to send you confirmations, updates, security alerts, and support and administrative messages, to detect and prevent fraud, and to otherwise facilitate your use of, and our administration and operation of, the Services;
- for market research in order to continually improve the products and services we deliver to you;
- to administer our websites and for internal operations, including troubleshooting, testing, statistical purposes;
- for marketing activities (e.g. to tailor marketing communications or send targeted marketing messages via social media and other third-party platforms);
- for the prevention of fraud and other criminal activities;
- to undertake credit checks for finance;
- to create a better understanding of you as a customer or visitor;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorized access;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for the purposes of corporate restructure or reorganization or sale of our business or assets;
- for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or our family of companies hold about you;
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
- for general administration including managing your queries, complaints, or claims, and to send service messages to you
- process your job application
- to comply with our legal obligations
- and for any other purpose for which the information was collected.
4. What Personal Information do we share with third parties?
We will not share the personal information we collect from you through the Services with third parties, except as described in this Policy or in the Services. We may share non-Personal Information, such as aggregate user statistics, demographic information, and Usage Information with third parties. We may also share your information as disclosed at the time you provide your information, as set forth in this Policy, and in the following circumstances:
THIRD PARTIES PROVIDING SERVICES ON OUR BEHALF
Service-Related Activities, Marketing and Promotions. In order to carry out your requests, to make various features, services and materials available to you through the Services, and to respond to your inquiries, we may share your Personal Information or Usage Information with third parties that perform functions on our behalf (or on behalf of our partners), such as companies or individuals that: host or operate our Services; analyze data; provide customer service; advertisers; sponsors or other third parties that participate in or administer our promotions or provide marketing or promotional assistance (such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list).
Financing and Credit-Related Services. If you apply for financing or credit through the Services, you may be required to provide certain Personal Information such as your address, credit information/history, employment and other financial information. We may share this information with the Servco Company you selected and our financial partners so that they can process your request and otherwise use the information you provided in accordance with their privacy policies. We will not use the personal financial information you provided for interest-based advertising.
SERVCO FAMILY OF COMPANIES AND BUSINESS TRANSFERS
Your Personal Information may also be used by us or shared with our subsidiaries, affiliates and other entities in the family of companies controlled by the Company for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or a portion of our assets, Personal Information, Usage Information, and any other information that we have collected about the users of the Services may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use information you have provided through the Services in a manner that is consistent with this Policy. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
5. Your California Privacy Rights
If you are a California resident and you decide that you do not want us to share your personal information with third party companies for their marketing and promotional purposes, please send an e-mail to email@example.com. In this e-mail, state that you would like the Company not to share your personal information with third parties for their marketing purposes. Your opt-out request will be processed within thirty (30) days of the date of which we receive it.
6. Advertising; How to Opt-Out
The Company licenses technology to serve advertisements on its own Services and within its content as that content is served across the Internet. In addition, we may use third party network advertisers to serve advertisements and third-party analytics vendors to evaluate and provide us with information about the use of the Services and viewing of our content. We do not share Personal Information with these third parties, but ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and access their own cookies, pixel tags and similar technologies on your Device and they may otherwise collect or have access to information about you, including Usage Information. We and our network advertisers may target advertisements for products and services in which you might be interested based on your visits to both the Services and other websites. We may use a variety of companies to serve advertisements. If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your information. To do so please visit the NAI Opt-Out Page. Please note that even if you choose to remove your information (opt out), you will still see advertisements while you are browsing online. However, the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.
7. Links to Other Sites
The Services may provide links to other websites that we do not own or operate. This includes links from advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. To the extent that any linked websites are not part of the Services, we do not control, recommend or endorse and are not responsible for these websites or their content, products, services or privacy policies or practices. These other websites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own privacy notices or policies. You should also independently assess the authenticity of any website which appears or claims that it is one of our Services (including those linked to through an email or social networking page).
8. How We Protect Personal Information
We maintain commercially reasonable administrative, technical and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Services and provide us with your information at your own risk. You are responsible for all uses of the Services by any person using your password. Please advise us immediately if you believe your password has been misused.
9. Updating, Correcting and Deleting Your Information
You can view and amend much of your information through your account. If you believe that information we maintain about you is inaccurate, subject to applicable law, you may request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below.
If we collect personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than necessary to perform under a contract with you, pursue our legitimate interests. We may need your personal information to establish, bring and defend legal claims, in which case we will retain your personal information for [X] years after the last occasion on which we have used your personal information.
10. Consent to Processing and Transfer of Information
The Services are operated in the United States. Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you access the Services, reside and/or are a citizen.
The Services are not directed to children under 16. We do not knowingly collect personally identifiable information from anyone under 16 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 16, we will make reasonable efforts to delete such information from our records. If you believe we may have any information from or about a child under the age of 16, please contact us at firstname.lastname@example.org.
This Policy and other information on the Services may be updated periodically and without prior notice to you, and any changes will be effective immediately upon the posting of the revised Policy on the Services. The “Last Updated” date at the top of this Agreement will indicate when the latest modifications were made. By continuing to access and use the Services after this Agreement has been modified, you are agreeing to such modifications. However, we will use your Personal Information in a manner consistent with the Policy in effect at the time you submitted the information, unless you consent to the new or revised notice.
13. How to Contact Us
If you have any questions or comments about our privacy practices or this Policy, please contact Servco Marketing/Online Services. We will address any issue to the best of our abilities as soon as possible.
By mail at:
Servco Pacific Inc.
Attn: Servco Marketing
2850A Pukoloa Street
Honolulu, HI 96819
By phone at: (808) 564-2356
By email at: email@example.com