PSL >> About PSL >> Privacy Policy

Privacy Policy

Last updated: 1 January 2020

Introduction

Product Safety Labs (the “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.  This policy describes the types of information we may collect from you or that you may provide when you visit the website www.productsafetylabs.com (our “Website”) and our practices for collecting, using, processing, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic communications between you and this Website.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.                                                                                                                             

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at DanMerkel@productsafetylabs.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see below regarding “Your California Privacy Rights” for more information.                                                                                                                           

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as (“personal information”):
    • information about your identity, such as your form of greeting, your last name, your first name;
    • information about your occupation such as the name of your company and the title of your position;
    • information on how to contact you such as your e-mail address, your professional direct phone, your professional direct fax, your mobile phone and your postal address;
    • information about your communication preferences such as the language and channel to be used;
    • information about your business interests;
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly, from you when you provide it to us.
  • Automatically, as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.
  • From third parties, for example, our business partners.                                                                                                                        

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further information or services.
  • Records and copies of your correspondence (including email addresses), if you contact us.

You should only give us the personal information requested in the web forms and if you do not agree to provide us with this information, you must not fill in the web forms. However, if you want to enter into a business relationship with us, you should provide us with the information necessary to enter into the relevant contracts and perform the relevant services.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.  This may also include user-behaviour tracker tool available on our CRM software (e.g., MailChimp) enabling us to know for example if you opened a newsletter or clicked on a link in order to optimise the content of our newsletters and their usability;   
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties.  It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see below regarding “Choices About How We Use and Disclose Your Information.”
  • , recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.                                                           

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide, administer and communicate with you about products, services, events, surveys and promotions by us or our affiliates (including by sending you marketing communications and newsletters);
  • To give you the possibility to attend our seminars and trainings;
  • To process, evaluate and respond to your requests and enquiries (including quote requests, documentation requests, free tests requests ), inquiries and applications (including for volunteer testings);
  • To create, administer and communicate with you about your account (including any purchases and payments);
  • To provide investor and customer services;
  • To evaluate your interest in employment (including current or future job positions) and contact you regarding possible employment;
  • To enter into a business relationship with you;
  • To ensure customers satisfaction through sending customers surveys;
  • To comply with laws and obligations we are subject to;
  • To maintain our software (including but not limited to bug fixes);
  • To gather statistics on your responsiveness towards our emails;
  • To be able to make your rights described below exercisable.
  • To help us contact you in any means.
  • To personalize your experience. Your information helps us to better respond to your individual needs.
  • To improve our Website. We continually strive to improve our Website based on the information and feedback we receive from you.
  • To improve customer service. Your information helps us to respond to your service requests and support needs more quickly.
  • To administer a contest, promotion, survey or other site feature that we occasionally manage.
  • To send periodic emails with announcements about our Company and services.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

For more information, see below regarding “Choices About How We Use and Disclose Your Information.”                                                                                                                                      

Processing and Disclosure of Your Information

We may process and/or disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may process and/or disclose personal information that we collect or you provide as described in this privacy policy:

  • For our legitimate interests (not for sensitive data), being
    • to ensure performance of a contract entered into with your employer;
    • to reply to your orders and inquiries;
    • to recruit candidates to fill in any of our present or future job vacancies within the Company or one of our affiliates;
    • to prevent fraud;
    • to direct marketing;
    • to establish, exercise or defend legal claims;
    • to transfer information within the group for administrative purposes;
    • to maintain (including but not limited to bug fixes) of our database.
  • To our trusted contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it based on our instructions and only in compliance with applicable privacy laws and regulations and for the purposes for which we disclose it to them.
  • To companies, organizations or individuals outside of the Company if we have a good reason to believe that access, use, preservation or disclosure of the information is reasonably necessary to:
    • execute and enforce contractual terms;
    • meet any applicable law, regulation, legal process or enforceable governmental request;
    • detect, prevent, or otherwise address fraud, security or technical issues;
    • protect against harm to the rights, property or safety of the Company, our users or the public as required or permitted by law;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other sale or transfer of some or all of the Company’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.  Please note, however, that you can withdraw your consent in full or in parts at any time by changing your preferences through a link provided in all emails footer or by contacting our contact point indicated below.

 

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings.
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes and the continuous improvement of the services provided under such contracts;
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.                                                                                                                                    

As noted above, we may disclose your personal information to any affiliate of the Company.  We do not sell or otherwise disclose personal information except as described above.

Your personal information will be stored for a limited period of time, determined with regards to the necessity to keep them in order to serve the purposes for which they have been collected and processed, as listed above.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.                                                                                                                   

Accessing and Correcting Your Information and Other Rights You May Have

You may have the right to access your personal information, to correct (rectify your personal information), to request the portability of your personal information, to restrict the processing and/or transferring of your personal information, and/or to erase your personal information.  You can inquire of these rights by contacting us at the contact information provided below.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. California residents may have additional personal information rights and choices. Please see below “Your California Privacy Rights” for more information.                                                                                                                       

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit PRIVACY NOTICE FOR CALIFORNIA RESIDENTS.                                                                                                                   

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.                                                                                                                           

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.                                                                                                                  

Contact Information

The person in charge of the control of any information obtained through this web form is the person identified below. To ask questions or comment about this privacy policy and our privacy practices, contact us at:

 

Dan Merkel

Product Safety Labs

2394 US Highway 130       

Dayton, NJ  08810 USA

Phone 732-438-5100 ext 4194

DanMerkel@productsafetylabs.com

Privacy Notice for California Residents

Effective Date: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in Product Safety Labs Website Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.                                                                                         

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.                                                                                                                         

In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

 

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

Yes

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

No

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Yes

G. Geolocation data.

Physical location or movements.

No

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

I. Professional or employment-related information.

Current or past job history or performance evaluations.

No

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

No

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

                                                                            

Our Website obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you -- for example, from forms you complete or services you purchase.
  • Indirectly from you - for example, from observing your actions on our Website.                                                                                                                             

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information with us to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry.
  • To provide, support, personalize, and develop our Website and services.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.                                                                                                                             

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have not disclosed personal information for a business purpose.[1]

Sales of Personal Information

In the preceding twelve (12) months, we have not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.                                                                                                                    

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.                                                                                                            

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights”), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

We do not provide these deletion rights for B2B personal information.                                                                                                    

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to:

Dan Merkel

Product Safety Labs

2394 US Highway 130        

Dayton, NJ  08810 USA

Phone 732-438-5100 ext 4194

DanMerkel@productsafetylabs.com

 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include you describing your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, if applicable, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

                                                                                                                                      

Personal Information Sales

We do not sell the personal information of consumers except as expressly set forth in the Product Safety Labs Website Privacy Notice.                                                                                                                                    

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

                                                                                                                                      

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to:

 

Dan Merkel

Product Safety Labs

2394 US Highway 130       

Dayton, NJ  08810 USA

Phone 732-438-5100 ext 4194

DanMerkel@productsafetylabs.com

                                                                                                                                      

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

                                                                                                                                      

Contact Information

If you have any questions or comments about this notice, the ways in which Company collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

 

Dan Merkel

Product Safety Labs

2394 US Highway 130       

Dayton, NJ  08810 USA

Phone 732-438-5100 ext 4194

DanMerkel@productsafetylabs.com