Privacy Policy

Phifer Incorporated (“we,” “us” or “Phifer”) is committed to protecting any Personal Data, which we define below, that you provide to us, or is otherwise collected, through your use of www.phifer.com (the “Web Site”). We collect this information to deliver you the best user experience possible as explained in more detail below. This Global Privacy Policy describes the types of Personal Data we collect, how we use the information, with whom we share it, and the choices you can make about our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. As used herein, all references to "Web Site" may include, individually, all and/or in any combination, of Phifer’s direct and indirect subsidiaries’ web sites and any other website produced, managed and maintained by Phifer.


When we collect information about you on our Web Sites, we will first obtain your explicit consent to do so by asking you to accept the terms of this Privacy Policy, if and as required by applicable law. By using any Phifer Web Site on which this policy is posted, you agree that this policy governs our collection, processing use, and disclosure of any Personal Data submitted to us on or through that Web Site.
For Web Site users from the European Union or European Economic Area


Legal Basis for Processing


We accept the transfer of and process your Personal Data, which we define below with your explicit consent and/or subject to the performance of a contract to which you as the Data Subject are a party or alternatively in order to take steps at your request to enter into an agreement with Phifer. You have the right to withdrawal your consent at any time.
Identification of Data Controller


The Data Controller is Phifer Incorporated. Phifer is located at 4400 Kauloosa Ave., Tuscaloosa, Alabama, 35401. You may contact Phifer by phone, please call 205-345-2120
Identification of Representative in the European Union.
Simona Visconti
Phifer Europe, SRL
GDPR@phifer.com

Identification of Data Protection Officer and Contact Details
William Cork
Phifer Incorporated
GDPR@phifer.com

Identification of Primary Member State Supervisory/Data Protection Authority
You have the right to lodge a complaint regarding the processing of your Personal Data with Data Protection Authorities in Italy. The Italian DPA is based only in Rome and may be reached using the information below:
Address:
Piazza di Monte Citorio, 121 – 00186 Roma
Phone: +39-06-6967 71
Fax: +39-06-6967 73785
Phone: +39-06-6967 71 / +39-06-6967 72917 
Certified mail:
protocollo@pec.gpdp.it
 Email: urp@gpdp.it

Information Collected From You
We collect two types of information about you when you visit our Web Site: Personal Data and non-personal, aggregate information (such as information regarding the pages on our Web Site that you have visited).


Personal Data
“Personal Data” is any information that identifies you, either directly or indirectly. This may include your name, address, telephone number, email address, date of birth, financial information, internet protocol (IP) address, and cookies. We collect, process and store the data that you have provided to us, or that is otherwise collected about you, through your use of the Web Site.
Here are some of the ways in which we may collect your Personal Data on the Web Site:
We collect information volunteered by you through our online forms and programs, email initiated by you, and site visit data.
During your visit to the Web Site you may initiate a transaction, such as requesting a quote or ordering a product. The information you provide for that transaction is collected and used by us to provide services, products, or information.
When you register on the Web Site, you may be required to give us some Personal Data to generate your account, such as your first and last name and email address.
We may collect your email address, first and last name, address, and zip code if you register for an event on the Web Site.
We may collect your name, email address and other data if you sign up for an online newsletter or contact us for any reason.
Like most web sites, when you use or access the Web Site or our services, we collect certain information automatically and store it in log files. Examples of information included in such log files are: IP addresses (which is Personal Data), browser type, referring/exit pages, operating system, date and time stamp, username (which is Personal Data), and pages visited.
The above list provides examples of the Personal Data that may be collected by Phifer. From time to time, we may collect Personal Data from you in other ways that are not described above.


Non-Personal Data
“Non-Personal Data” is information that CANNOT be used identify you, directly or indirectly.
We may conduct research on our users’ demographics, interests, and behavior based on the information provided to us from our server log files or from surveys. We do this to better understand and serve you. This research is compiled and analyzed on an aggregated basis.
We may combine non-identifying, automatically collected log information with the Personal Data we collect from you. We do this to improve our services, marketing analytics, and the functionality of the Website.
Finally, Phifer may combine any public information you provide in any of the public areas on the Web Site with non-personally identifiable information to create aggregate data. This information may also be disclosed to third parties. Aggregate data does not contain any information that could be used to contact you or identify you personally.


Cookies
When you use or access the Web Site or our services, we (and our advertisers, business partners, and other companies that help us render the services and operate and maintain the Web site) may, and may permit its partners to, place small data files on, or otherwise create and store a unique anonymous identifier that may be code, first-party, or other cookies, beacons, pixel tags, scripts, cookies, or other local storage provided by your browser or associated applications (collectively, “Cookies”).
We may use these Cookies to analyze trends, administer and track use of the Web site, and to gather demographic information about our user-base as a whole. Moreover, we may use Cookies to: (a) recognize you; (b) verify your identity; (c) customize our services and advertising; (d) help ensure that your account security is not compromised; (e) collect traffic data, such as whether you are a new or returning visitor, the time stamp of your current visit to the website, and the referrer site or campaign that directed you to our services or products (e.g., search engine, keywords, banner or email); and (f) mitigate risk and prevent fraud through our services. We may receive reports based on the use of these technologies by third party companies on an individual as well as aggregated basis. We may also use third party services (such as Google Analytics) to help analyze how users use the Website and services, and these third-party services may place Cookies on your device to collect certain internet log information and visitor behavior information in anonymous form.
If you click on a link to a third-party website, such third party may also transmit Cookies to you. This Privacy Policy does not cover the use of Cookies by any third parties.


Do Not Track
If your browsers “Do Not Track” signal is on, we will not track your activities on our Web site or use tracking Cookies on your browser, however, doing so may interfere with your use of the services or features of the Web site. If your settings block Cookies and tracking, you may not be able to take advantage of the personalized features enjoyed by other users of our Web Site.
We also may collect non-personally identifiable information from you in order to customize your experience, fulfill your requests for information, and improve our services. We may provide this non-personally identifiable information to third parties. For example, we might inform third parties about the number of users of our Web Site and the activities they conduct while on the Web Site. We also may provide trusted partners with general information regarding our users and visitors.


Use and Disclosure of Information


Personal Data
We may use or share or disclose your Personal Data in the following instances:
To deliver services or products, such as information or newsletters you request, or to complete or communicate with you about your account or transactions with you, and to offer customer support. We may use your personally identifiable information to contact you about products or services that we believe may be of interest to you.
Resolve disputes, collect fees or enforce a service or product agreement, and to troubleshoot problems.
To contact you in response to sign up forms such as Contact Us.
To alert you to special offers, updated information and other new services from Phifer, or other third parties, or to forward promotional materials, or to send you newsletters.
To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Web Site and provide other administrative services to us or that help us provide services or products to you (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, financial and other institutions that provide the billing, payment processing, funds transfer and services necessary to facilitate the provision of services or products), or that provide associated services to you with our services (such as warranty repair providers).
To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties offering products or services that we believe may be of interest to you or who require your personally identifiable information for research, administrative and/or internal business purposes. These parties may use your personally identifiable information to contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes. If you do not want us to share your personally identifiable information in this manner, please do not provide us with this information.
Service providers who help with our business operations, such as fraud prevention, bill collection, marketing and technology services.
To ensure the Web Site is relevant to your needs.
To help us create and publish content most relevant to you.
To communicate with you and send information about features on the Website and to notify you about a material change to this Privacy Policy or the Terms of Use, if necessary.
To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property or act in urgent circumstances to protect the personal safety of our end users.
To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, or sales of all or substantially all of our assets.
To track and analyze non-identifying and aggregate usage and statistical information from our visitors and customers and provide such information to third parties.
To handle any physical or other type of threat made to you or others, to protect property or to defend or assert legal rights.
Except as described in this Privacy Policy or at the time we request the information, we do not otherwise use, share or otherwise disclose your Personal Data to any third parties.


Non-Personal Data
Non-personally identifiable information is used and disclosed as described above and in other ways as permitted by applicable laws, including combining non-personally identifiable information with personally identifiable information.

III. Your Choices:
Right of Access to your Personal Data
Data Subjects have the right to access the Personal Data an organization holds about them. If such Personal Data is inaccurate or processed in violation of the GDPR, a Data Subject may also request that Personal Data be corrected, amended, or deleted. When Phifer receives Personal Data, it does so on behalf of the individual submitting such Personal Data.  To request access to, or correction, amendment or deletion of, Personal Data, Data Subjects should contact the Phifer’s Data Protection Officer.  Phifer will cooperate with all reasonable requests to assist Data Subjects to exercise their rights under the GDPR.

Choice
Data Subjects have the right to opt out of (a) disclosures of their Personal Data to third parties not identified at the time of collection or subsequently authorized, and (b) uses of Personal Data for purposes materially different from those disclosed at the time of collection or subsequently authorized.  Data Subjects who wish to limit the use or disclosure of their Personal Data should submit that request to Phifer’s Data Protection Officer. Phifer will cooperate with the Data Subjects’ instructions regarding Data Subjects’ choices.
You may request not to receive newsletters, alerts, offers and promotions for our products and services, or products and services that we think may be of interest to you.
You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Although you are free to decline our Cookies.
if your browser permits, doing so may interfere with your use of the Services. For example, you may not be able to access certain aspects, or all, of the functionality of the Services if you decline, reject or delete Cookies, and may not be able to complete the log-in process at all, because we will be unable to authenticate you as an authorized user. Refer to the help section of your browser, browser add-on or extension, or installed applications for instructions on blocking, deleting or disabling Cookies.
California Privacy Rights: Under California Civil Code Sections 1798.83-.84, California residents may ask us for a notice (a) identifying the categories of personally identifiable information which we share with our affiliates and/or third parties for marketing purposes, and (b) providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please contact us at
info@phifer.com.

Suggestions You Make to Us
This Privacy Policy does not apply to any content, business information, ideas, concepts or inventions that you may elect to send to Phifer by email or post anywhere on the Web Site. If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them in an email to Phifer or post them in any way.

Children Under the Age of 13
Neither Phifer nor its Web Site are designed or intended for children under the age of 13. We do not collect personally identifiable information from any person we actually know is under the age of 13.

Links to Third Party Sites
From time to time, Phifer may offer you content through a web site hosted and operated by a third party. In addition, the Web Site may contain links to other third party web sites operated by companies that are not affiliated with Phifer and that do not have contracts to provide content or services through Phifer. These links may be found in advertisements, referenced within content, or placed beside the names or logos of sponsors. Phifer does not endorse and is not responsible for the privacy practices of these sites. If you choose to link to one of these third party web sites, you should review the privacy policy posted on such a web site to understand how that web site collects and uses your personally identifiable information.
The Web Site and Services may include certain social media features, such as the Facebook and Twitter buttons or interactive mini-programs that run on our Website. These features may collect your Internet protocol address, which page you are accessing and using on the Website, and may employ the use of Cookies to enable the feature to function properly. Social media features or widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy notice of the company providing the social media feature.

Onward Transfer

Phifer will not disclose Personal Data of Data Subject from the EU or EEA to a third party, except as stated below:

Phifer may disclose Personal Data to subcontractors and third-party agents as described above in this Privacy Policy. Before disclosing Personal Data of EU and EEA Data Subjects to a subcontractor or third-party agent, Phifer will obtain assurances by contractual agreement from the recipient that it will: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the subcontractor or third-party agent is obligated to provide at least the same level of privacy protection as is required by the General Data Protection Regulation (“GDPR”); (iii) take reasonable and appropriate steps to ensure that subcontractors and third-party agents effectively processes the Personal Data transferred in a manner consistent with the organization’s obligations under the GDPR; (iv) require subcontractors and third-party agents to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the GDPR; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with subcontractors and third-party agents to the Supervisory Authorities upon request.

Phifer may also be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements or in the event of a merger or acquisition.

Data Integrity:
 
Phifer responsible for ensuring that (a) Personal Data collected is accurate, complete, current and reliable for its intended uses; and (b) Personal Data is retained only for as long as is necessary to accomplish the legitimate business purposes disclosed to the Data Subject and for any compatible purposes. Phifer will cooperate with reasonable requests for assistance in meeting these obligations.
Retention of Personal Data:
Personal Data obtained by Phifer is adequate, relevant and not excessive in relation to the purposes described in this Privacy Policy. The Personal Data is processed for purposes specified herein and will only be processed consist with these purposes described herein. Phifer will request only the minimum amount of information required to perform the applicable services and will retain such information only for as long as necessary to provide the services or for compatible purposes, such as to provide additional services, to comply with legal requirements, or to preserve or defend Phifer’s legal rights.

Transfers to the United States from the European Union:

Phifer may transfer Personal Data is receives at the point of collection and transfers it to the United States which is not recognized as a country having adequate safeguards for the protection of Personal Data. Phifer relies on Article 49 of the GDPR for transfers data collection from Data Subject in the EU and EEA. Transfers made to Phifer are in cases where the data subject has consented to the proposed transfer after having been informed of the possible risks of such transfers. Additionally, Phifer transfers data as necessary for the performance of a contract between you as the data subject and Phifer as the Controller or in cases where your Personal Data is necessary for the implementation of pre-contractual measures taken in accordance with your requests.

Changes to this Privacy Policy
We reserve the right to change this Privacy Policy from time to time. When we do, we will also revise the “last update” date at the bottom of this Privacy Policy. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information you have provided to us, we will attempt to obtain your consent before implementing the change by sending a notice to the primary email address specified by you or by placing a prominent notice on the Web Site.

How Phifer Handles Privacy and Security Internally
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. We take commercially reasonable measures to ensure that your Personal Data remains secure.

Contacting Phifer
If you have any questions about this Privacy Policy or our privacy practices, please contact us at
info@phifer.com All information you provide in any written communication will also be covered by this policy.