LAST UPDATED: January 16, 2019
- Through our software applications made available by for use on or through computers and mobile devices (the “Apps”),
- Offline such as when you visit our stores or retail kiosks, attend a tradeshow, or place an order or request for support over the phone.
Collectively we consider the Sites, Apps, Social Media Pages, and offline the “Services”.
- What Personal Information does easystrap collect about you?
- How do we use the Personal Information we collect about you?
- Does Easystrap share your Personal Information with third parties?
- What Other Information about you does Easystrap collect?
- How are our advertisements served on other websites and devices and what choices do you have?
- What choices do you have over how we use and disclose your Personal Information?
- How does Easystrap secure your Personal Information?
- How can you access, change, or delete your Personal Information?
- Third party services
- Cross-border transfer
- Retention period
- Use of services by minors
- Sensitive information
- Third party payment services
- How can you contact Easystrap?
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
We and our service providers may collect and combine Personal Information about you from a variety of sources, including:
- Through the Services, for example, when you sign up for a newsletter, marketing emails and other commercial electronic messages (e.g., on upcoming promotions, new products, etc.), register an account to access the Services (e.g. to register your products, to ask for support, to participate in our contests or competitions, to make inquiries regarding product warranties), or make a purchase, or through our Social Media Pages.
- From Other Sources. We receive your Personal Information from other sources, for example:
- Publicly available databases, such as LinkedIn or local Trade or Industrial Associations’ registries.
- Joint marketing partners, when they share the information with us, including: privately held marketing or survey / enquiry databases.
- If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account, depending on the preferences / choices you have selected within your social media account’s setting, or the opinions expressed (e.g., “Likes”) you have provided within our Social Media pages.
We generally collect the following types of Personal Information:
- Your Name
- Mailing address
- Email address
- Telephone number
- Mobile phone number
- Postal/zip code, state/province, and country
- Username and password (related to your account)
- Purchase, order information and payment details
- Demographic information (for example number of household members, country of residence, age and gender)
- Information related to customer satisfaction surveys, customer requests or queries
- Purchasing habits and other information, including registration of products purchased
- Interests and hobbies
- Information on products you want, like or own
- Bank information (e.g. for special offers – reimbursement, warranty extension, prizes or contests)
On certain Sites, we allow you to use your personal social media account, on social media sites (“Personal Social Media Account”), to provide Personal Information to us when you participate in certain features on our Sites. This Personal Information may include the following:
- Your name and/or nickname
- Profile picture
- User id
- List of friends and related contact details
- Voice recordings
- Video and photographs
- Work history/Profession
- “Likes” or online group membership
- Opinions expressed (e.g. when replying around the satisfaction about one of our products)
It is also possible that we will be able to continue collecting this information from your Personal Social Media Accounts should the information be revised by you later.
We need to collect Personal Information in order to provide the requested Services to you. You may choose not to provide us with certain requested information, but then you might not be able to take advantage of some of our Service features or we may not be able to provide you with the Services.
The Personal Information we collect from you helps us personalize your experience with us and our communications to you, and helps us continually improve your experience with our Services. We and our service providers use the Personal Information collected above for the following purposes including:
- Providing the functionality of the Services and fulfilling your requests, including:
- Opening and arranging access to your registered account.
- Responding to your inquiries and fulfilling your requests for example when you contact us via one of our online contact forms or chat lines.
- Processing your order or other transactions, including warranty and product registration, claim, or request, and providing related customer service.
- To send administrative information to you, such as changes to our terms, conditions and policies.
- To allow you to send messages to another person if you choose to do so.
We will engage in these activities to manage our contractual relationship with you, and/or to take steps at your request prior to entering into a contract, and/or to comply with a legal obligation.
- Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
- To send you advertising and marketing related emails, text messages, and postal mail with information about our services, new products and other news about our company.
- To facilitate social sharing functionality that you choose to use.
- To send wish lists or other emails on your behalf.
We will engage in this activity with your consent.
- Analysis of Personal Information for business reporting and providing personalized services.
- To better understand you, so that we can personalize your experiences when using our Services, and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used and perform market research, so we can improve our Services.
We will provide personalized services either with your consent or because we have a legitimate interest.
- Allowing you to participate in sweepstakes, contests or other promotions.
- We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
- Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.
We use this information to manage our contractual relationship with you.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
- Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
- For improving and developing our products and services.
- For enhancing, improving, or modifying our current products and services.
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
- For facilitating recalls.
- For processing job applications.
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
If you sign-up for our email list, we may use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please contact us as detailed at “16. How can you contact Easystrap?” below.
We may share your personal information with the following:
- Our third party service providers, including distributors and sales representatives, in order to perform tasks on our behalf, such as:
- Facilitating your purchase, order fulfillment, and payment processing
- Assisting in servicing our products
- Product registrations
- Responding to requests and providing product information
- Helping you exchange products and other customer service tasks
- Providing and improving our communications with you
- Responding to requests to our investor relations
- Providing website hosting, data analysis, information technology and related infrastructure provision
- Advertising and analytic services
- Email delivery
- Notifying you if you have won a contest or a competition we have conducted and delivering to you the contest’s prize
- Conducting a survey or a customer satisfaction enquiry
- Responding to complaints or product claims requests (for warranties extension, injuries, damages, etc.)
- Other services
For additional information about the way in which our third party service providers treat your personal information, contact us as set out below.
- To our licensees and franchisees for their use in relation to the marketing, distribution, advertising sale and servicing of products sold under license from us.
- To third party business partners, who may contact you about their own products or services that may interest you, consistent with your choices.
- By using the Services, you may elect to disclose Personal Information:
- On message boards, public chat rooms, profile pages, blogs, research panels and communities, surveys, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures of Personal Information
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law.
- This can include laws outside your country of residence.
- To respond to requests form public and government authorities.
- This can include laws and authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests or orders.
- For other legal reasons, including:
- To protect our rights, property or safety, and/or that of our users, you, our or others.
We have a legitimate interest in disclosing or transferring some or all of the Personal Information collected about you to a third party if Easystrap were ever merged with or acquired, or involved in a corporate reorganization, joint venture, assignment, sale, or transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Other Information includes:
- Browser type and version
- Operating system
- IP Address (see below for further information)
- The Internet service provider used to access our Services
- Use of links to arrive at our Services and the IP address from which you arrived
- Web pages requested and viewed
- Time spent on our Services
- For our mobile websites and apps, technical information about the device used, such as screen size, cookie support by the device and how images may appear
- App usage data
- Other information collected through cookies, pixel tags, and other technologies described below
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the 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 the Services. We may also derive your approximate location from your IP address (see “Location” below).
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
We and our service providers collect Other Information in a variety of ways, including:
- Through your browser or device:
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the Apps) you are using. We use this information to ensure that the Services function properly.
- Through your use of the Apps
- When you download and use the Apps, 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.
- Physical Location Information
- Our Services and HTML-formatted emails include features that may require collecting different types of location information (such as IP Address, GPS coordinates or postal code) that we then use for the specific feature you have selected, such as:
- Where to Buy and Store Locator. Some of our Services allow you to search for the nearest store that offers the Easystrap product that you want and whether such nearby stores have certain of our items in stock. If you access one of our Sites or Apps through a mobile device and you have enabled location-based services, location information may be collected for these features, by, for example, using satellite, cell phone tower or WiFi signals. If you access these features through a desktop device, you can choose to have your browser provide us your location information based on your IP Address to respond to your request, or you may be asked to provide us with your location information. The specificity of the desktop device location information can vary depending on the browser you are using and how you are connected to the internet. Your mobile device settings may allow you to disable location-based services, which will prevent our Sites and Apps from accessing your precise mobile device location information. We recommend you review the help or user manual provided with your device for instructions.
- Email. Our emails use your IP Address to determine the postal code where you are located when you open the email. This allows us to tailor content to you, such as a map of nearby stores carrying our products. The specificity of the location can vary depending on the device used to open our emails. Your email program may allow you to prevent the pixel tags or images in the emails you receive from us from downloading, which will also prevent our service provider from accessing your location information. You can also unsubscribe from receiving our emails, as described in Section 6 below.
- Bluetooth® Enabled Products and Services. This section applies to additional personal information that may be collected, used, and disclosed related to our Bluetooth® enabled products and related Services (collectively our “Bluetooth® Enabled Products and Services”). If you access our Bluetooth® Enabled Products and Services through a mobile device, we may collect and use your mobile device’s location services and Bluetooth® capabilities to identify the date, time and location of your mobile device when it was last in Bluetooth® range of a registered, Bluetooth® Enabled Product. This is done to assist you in locating a registered Bluetooth® Enabled Product. We may also collect location information about your registered Bluetooth® Enabled product as sent to us via other users’ mobile devices, and location information about other users’ registered Bluetooth® Enabled products as sent to us via your mobile device. (Bluetooth® is a registered trademarks owned by Bluetooth SIG, Inc. and any use of such marks by Easystrap is under license). You may avoid collection of this data by disallowing the Services from accessing Bluetooth® on your device through your device settings or in some cases, at the time you install the App, but we may not be able to provide all features of the Services to you.
- We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns.
- Our Services and HTML-formatted emails include features that may require collecting different types of location information (such as IP Address, GPS coordinates or postal code) that we then use for the specific feature you have selected, such as:
- If you do not consent to provide location information or you disable location-based services on your mobile device, we may ask you to manually select the region where you are located, or to enter your zip or postal code. Your desktop or mobile device settings may allow you to disable or block location-based services, which will prevent our Services from accessing your location information. We recommend you review the help information or user manual provided with your device or browser for instructions. If you chose not to provide this information you may not be provided with content specific to your location and we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
- We and our third party service providers use “cookies”. Cookies assign a unique identification to your device and are typically stored directly on your device by your web browser.
- The information we and our third party service providers collect through cookies, pixel tags and similar technology includes the following:
- Your interactions with our Services and with our advertisements
- The time of your visit to our Services
- Items and products browsed, items put into your shopping cart, and whether you purchase any or all of those items
- Confirmation when you open email from us, including the time you open the email and whether you click on any links in the email
- Sites you visit after visiting one of our Sites
- Language preferences
- Other traffic data
- We also gather statistical information about use of the Services in order to continually improve their design and functionality, to improve and better transact business, to understand how Services are used, measure which parts of our Sites are most visited or used, monitoring the number of visitors to our Sites, and assist us with resolving questions regarding the Services.
- Pixel tags and other similar technologies
- We may also use pixel tags (also known as web beacons, web bugs, and clear GIFs) in providing the Services. A pixel tag is a nearly invisible pixel-sized graphic image on a webpage or in an email message. We use these technologies to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, measure which parts of our Sites are most visited or used, and compile statistics about usage of the Services and response rates.
- Third-party analytics
- Other Information from Social Media Pages
- Similar to the navigational information described above, the social media sites where we have our Social Media Pages may provide aggregate information and analysis to us about visitors to our Social Media Pages. This allows us to better understand and analyze our user growth, general demographic information about the users of, and interaction with content on, our Social Media Pages.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies
- We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
- We additionally use Other Information gathered through technology for identifying and addressing difficulties visitors may experience in accessing our Services.
We contract with third party advertising companies to tailor online advertising to be directed to you on other websites and online services. These third party advertising companies place, use, or rely on technology, such as cookies and pixel tags, to obtain information about your interactions with our Services. This information, in addition to information the companies receive from your access to and use of other websites or online services on any of your devices, and information received from third parties, helps us select advertising to serve to you and where to serve it based on your experience on our Services and other sites that you visit. They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.
Note that by clicking these websites, you will then leave our Site for another online site where you may specify your preferences under that opt-out program. You can also click the preference icon that may appear on some of our advertising served through these technologies.
We give you choices about the information we collect and how we communicate with you, and use and disclose your information.
a. Email: You may opt-out of our marketing emails by following the instructions listed in the email that you received. However, even if you opt-out you may still receive non-marketing emails, such as order/shipping confirmations, changes to service, product registrations, product recalls or customer service communications.
b. Text messaging/IM: You may opt out of mobile text messages (e.g., SMS, MMS) and other instant messages (e.g., WhatsApp, Facebook Messenger) from us, by following the opt-out instructions accompanying such messages, if applicable, or by contacting us as detailed at “16. How can you contact Easystrap?” below.
d. Postal Marketing: If you no longer want to receive marketing materials from us via regular postal mail, please contact us as detailed at “16. How can you contact Easystrap?” below, and tell us that you want to be removed from the Easystrap postal mailing list, including the postal address you wish to have removed.
f. Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by contacting us as detailed at “16. How can you contact Easystrap?” below.
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.
We have implemented reasonable technical, administrative and physical measures designed to protect the personal information in our custody or control from unauthorized access, use, modification and disclosure.
If you are using one of our Services with an online store, we designed our online store to accept orders only from Web browsers that permit communication through Secure Socket Layer (SSL) technology, which encrypts your information while it is being transmitted to us. Browsers that do not meet this requirement will be prevented from navigating the online store section of our Services.
You should be aware that 100% security of data transmission or storage is not always possible. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “16. How can you contact Easystrap?” section below.
If you would like to request to access, update, correct, suppress, restrict, or delete Personal Information previously provided to us, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you can do this by emailing or writing to us as detailed in the Section “16. How can you contact Easystrap?” below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records. We will try to comply with your request as soon as reasonably practicable.
Please note that 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 (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to us at the contact information set out below. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
You may also access, update and correct inaccuracies in certain Personal Information through your account for certain Services.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you are located in the EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these standard contractual clauses here.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Please note that where you unsubscribe from our marketing communications, we will keep a record of your e-mail address to ensure we do not send you marketing e-mails in the future.
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
We ask that as a general matter you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise to us. In the event you choose to submit such information to us, or are requested to do so by us in the course of investigating a complaint or dispute involving the Services, we shall collect and process such information in compliance with applicable law.
205 Constitution Drive
Menlo Park, California 94025
Please include your question or request in your email or letter to us, including the SBD brands and Services relevant to your request.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
Additional information for the EEA
In the EEA, you also may:
- Contact our data protection officer responsible for your country or region. Find out which data protection officer is responsible for your country or region by mailing us.
- Lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of EEA data protection authorities is available here.
Effective as of: January 16, 2019