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PRIVACY POLICY

We recommend that you read this entire Privacy Policy to ensure you are fully informed.

PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

We may collect personal information from individuals through our websites or by other means (such as email, fax, mail, phone, mobile applications, third-party applications, our parent, subsidiary, or affiliate companies, business partners and other third-parties such as commercial data vendors and public databases).  The principal ways you may provide the information and the types of information you may submit, as well as the ways we may use the information, are listed below. 

Business Alerts, Newsletters and Other Communications – You may provide personal information such as your name and contact details to receive business alerts, newsletters and other communications (including emails).  It is in our legitimate business interests to use the information you provide to send you the communications and information you have requested and to communicate with you about our products and services. If you no longer want us to send you business alerts, newsletters or other communications, you may unsubscribe at any time by contacting us via the contact information provided in the "How to Contact Us" section of this Privacy Policy.

You may also choose to connect to us via social networking services (e.g., Facebook or Twitter).  When you connect to us via a social networking service, we may collect personal information that you have provided to that service in accordance with the service’s applicable Terms of Use and your privacy settings within that social networking service.  We may also choose to supplement information you have provided to us by obtaining additional demographic information about you from third-party sources in order to improve our communications with you, give us better insight into your needs, and improve our business where permitted under local law.

Feedback – You may be able to submit feedback on our websites.  If you choose to give us your feedback, we may ask you for your personal information.  We may also ask you about your experience using our websites.  It is in our legitimate business interests to use the information you provide to enhance our websites, evaluate the quality of our products, or to communicate with you about products and services. 

Information Technology/Physical Security – We may collect personal information when detecting and defending against security threats in accordance with our legitimate business interests and our legal obligations.  We use various IT tools to detect and defend against online security threats (e.g., attacks, viruses, malware, spam, phishing, malicious web content), to promote business continuity of our information systems and assets, and to maintain optimal performance of our IT systems. Likewise, to ensure physical security of our facilities we may, where permitted under local law, document your presence or verify your identity, use surveillance systems and/or location tracking while you are on Company property.

Other Uses of Information – We may use the personal information you provide to us for internal general business purposes in accordance with our legitimate business interests.  These purposes include administration of our websites, data analytics, fraud prevention and compliance with our legal obligations, standards, policies and procedures (i.e., due diligence checks and sanction screening where applicable). 

INFORMATION WE COLLECT BY AUTOMATED MEANS

When you visit and interact with our websites and applications, we may collect "Other Information" that does not inherently reveal your specific identity, in order to learn how to best tailor our websites for our visitors.  Examples of what Other Information we may collect and how we and third-party service providers may collect this information include:

Aggregation Information – Aggregated user information does not personally identify you or any other user (for example, we may aggregate user information to calculate the percentage of our users who have a particular telephone area code).  Aggregated data is treated in accordance with this Privacy Policy.

App Usage Data – When you download and use an app, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number.

Browser and Device Information – Certain information is collected by most browsers or automatically through your device, such as your computer type, operating system name and version, device manufacturer and model, Internet browser type and version and the name and version of the online services (such as the apps) you are using.  We use this information to ensure that the online services function properly.

Cookies – Cookies are pieces of information stored directly on the computer or mobile device that you are using.  Cookies allow us to collect information such as browser type, time spent on the online services, pages visited, referring URL, and other aggregated website traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information, and to personalise your experience while online.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You can choose whether to accept cookies by changing the settings on your browser or, depending on your jurisdiction, by managing your tracking preferences as noted in a separately posted cookie statement or via a posted cookie manager.  If, however, you do not accept cookies, you may experience some inconvenience in your use of the online services.  For example, we may not be able to recognise your computer, and you may need to log in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs. 

IP Address – Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP).  An IP address may be identified and logged automatically in our server log files whenever a user accesses the online services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services.  We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our online services.  We may also derive your approximate location from your IP address to understand from what regions of the world our website visitors come.

Geolocation Based Services – We may collect geolocation data (i.e., the physical location of your device) if you have consented to us doing so, by, for example, using satellite, mobile phone tower, Wi-Fi signals, or other technologies. We may use your device’s physical location to provide you with  location-based services and content.

We also use Google Analytics and Facebook Pixels, which uses cookies and similar technologies to collect and analyse information about use of our services and report on activities and trends.  These services may collect information regarding the use of other websites, apps and online resources. 

WITH WHOM WE SHARE YOUR INFORMATION

We do not sell your personal information.  We may share your information as disclosed at the time you provide it and/or in the following circumstances:

Business Transfers – We may disclose your personal information, usage information, and other information about you to parties acquiring part or all of our assets, as well as to attorneys and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Privacy Policy.  Also, if any bankruptcy or reorganisation proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.

Law Enforcement Agencies, Courts, Regulators, Government Authorities or other Third Parties – We may transfer and disclose your information to third parties (i) to comply with a legal obligation, (ii) when we believe in good faith that the law requires it, (iii) at the request of governmental authorities conducting an investigation, (iv) to verify or enforce our policies, Terms of Use and other agreements or to protect the rights, property, or safety of Koch Industries, our customers, or others (v) to respond to an emergency, (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity or (vii) otherwise to protect the rights, property, safety, or security of third parties, users of our services or the public.

Marketing Partners – In some cases, we may permit certain network advertising companies and publishers to collect personal information on our sites.  In addition, and when permitted by law, our business partners may access personal information about you that we have combined with such business partners’ data. This collaboration with our business partners using the combined set of information is to jointly send tailored promotional communications to you.  If you prefer not to receive these joint communications, you can opt out by following the instructions included in any such communication.

Business to Business Transactions – We make available certain apps that facilitate transactions between businesses (for example, shipping apps that assist with load delivery or pick-ups).  If you use one of our business apps, we may share your information with other users of the app to facilitate transactions and communications between you and other users. 

USER-GENERATED CONTENT

Some of our services and social networking features may enable you to submit your own content for public posting.  Information you post in this fashion becomes public information and is not subject to this Privacy Policy. 

LINKS TO OTHER SITES

Our websites and communications may provide links to other websites, including to social networks or partners that may use our logo(s) as part of a co-branding agreement.

HOW WE PROTECT PERSONAL INFORMATION

In proportion to the sensitivity of the information, we maintain reasonable administrative, technical and/or physical safeguards and appropriate security measures to protect personal information from loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide.  However, we cannot guarantee the security of your personal information, as no electronic data transmission or storage of information is completely secure. If an incident is reported affecting your information, we will investigate and comply with all required reporting obligations.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy or if you would like us to remove or update information we have about you or your preferences, please contact us.

Email: softerpaper@gmail.com