This Privacy & Cookies Statement describes how Hallstar Innovations Corp. (the “Company“) collects, uses, shares, and otherwise processes individually identifiable data about visitors to this Site (defined below) as well as contact persons for our customers, distributors, sales representatives, end users, and suppliers (“Personal Data“). This Privacy Statement applies to Personal Data that we collect through our public websites and other online properties (each, a “Site“), as well as through trade shows and offline means.
|Collection||As a business to business (“B2B“) organization, we collect name, contact details, and other Personal Data related to our commercial relationships.|
|Use||We use Personal Data to perform transactions and respond to inquiries, to manage accounts and maintain business operations, to provide relevant marketing, and to fulfill other business and compliance purposes.|
|Sharing||We share Personal Data as necessary to perform transactions and respond to requests, and to fulfill other business and compliance purposes.
You have choices on how we use Personal Data for marketing.
|Marketing choices||You have choices on how we use Personal Data for marketing.|
|Data subject rights||You have certain rights to request access, rectification, deletion, or other actions regarding your Personal Data where required by applicable law.|
|Data security||We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction.|
|Cross-border data transfers||We provide appropriate protections for cross-border transfers where specified by law.|
|Other issues||We provide other information in this Privacy & Cookies Statement about: (i) the legal basis for our collection and processing of Personal Data, (ii) the consequences for not providing Personal Data; (iii) automated decision-making; (iv) do-not-track (DNT) signals; (v) data retention; (vi) links to third-party websites; and (vii) changes to this Privacy & Cookies Statement.|
|Contact us||Please contact us as detailed below with any questions.|
We collect the following categories of Personal Data:
Basic Data: Name, title, company, job responsibilities, phone number, mailing address, email address, and contact details.
Registration Data: Newsletter requests, subscriptions, downloads, and username/passwords.
Transaction Data: Transaction history, payment details, and performance data.
Marketing Data: Data about individual participation in trade shows and conferences, credentials, associations, product interests, and preferences.
Compliance Data: Government identifiers, passports, beneficial ownership data, and due diligence data.
Job Applicant Data: Data provided by job applicants or others on our Sites or offline means in connection with employment opportunities.
Device Data: Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites (Usage Data). Note, however, we do not consider Device Data to be Personal Data except where we link it to you as an individual or where applicable law provides otherwise.
We use the following categories of Personal Data for the following purposes:
|Purpose of Use||Categories of Personal Data|
|To perform transactions and respond to inquiries||Basic Data, Registration Data, Transaction Data, and Device Data|
|To manage accounts and maintain business operations||Basic Data, Registration Data, Transaction Data, and Device Data|
|To make our Sites more intuitive and easy to use||Device Data|
|To protect the security and effective functioning of our Sites and information technology systems||Basic Data, Registration Data, Transaction Data, and Device Data|
|To provide relevant marketing||Basic Data, Registration Data, Transaction Data, Device Data, and Marketing Data|
|To address compliance and legal obligations||Basic Data, Registration Data, Transaction Data, Device Data, and Compliance Data|
|To use in considering individuals for employment and contractor opportunities, as well as to manage on-boarding procedures||Job Applicant Data|
We share Personal Data with the following categories of recipients:
You have control regarding our use of Personal Data for directing marketing. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication or contact us as per below.
What are cookies?
Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website. More information about cookies and how they work is available at www.allaboutcookies.org.
Cookies on our Sites are generally divided into the following categories:
What are your options if you do not want cookies on your computer?
You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Sites, and you may be required to re-enter your log-in details.
To learn more about certain cookies used for interest-based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings if you have the DAA or other mobile app.
Where required by applicable law, you have the right to obtain confirmation of the existence of certain Personal Data relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us as detailed below. In particular, you have the right to object to our use of Personal Data for direct marketing and in certain other situations at any time. Contact us below for more details.
We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration or unintentional destruction. However, no security measure can guarantee against compromise. You also have an important role in protecting Personal Data. You should not share your username and password with anyone, and you should not re-use passwords across more than one Site. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.
We transfer Personal Data to jurisdictions outside your home country as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers. With respect to transfers originating from the European Economic Area (“EEA“), we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required by applicable law. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.
(i) What is the legal basis of processing?
Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including: (a) as necessary to perform a transaction (such as when we respond to your requests); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for recordkeeping to substantiate tax liability); (c) consent (where you have provided consent as appropriate under applicable law); and (d) as necessary for legitimate interests (such as when we act to maintain our business generally). With respect to legitimate interests, given that we are a B2B company, we typically collect and process limited Personal Data about customer contacts and other individuals acting in their business capacities, as part of our overall effort to reduce the privacy impact on individuals.
(ii) What are the consequences of not providing Personal Data?
You are not required to provide all Personal Data identified in this Privacy & Cookies Statement to use our Sites or to interact with us offline, but certain functionalities will not be available if you do not provide Personal Data. For example, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.
(iii) Do we engage in automated decision-making without human intervention?
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
(iv) Do the Sites honor do not track (“DNT”) signals sent via browsers?
Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time.
(v) How long do we retain Personal Data?
We typically retain Personal Data related to marketing activities for as long as you accept marketing communications from us, and we will securely delete such data in accordance with applicable law upon request. For Personal Data that we collect and process for other purposes, we typically retain such Personal Data for no longer than for the period necessary to fulfill the purposes outlined in this Privacy & Cookies Statement and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.
(vi) Are third-party websites governed by this Privacy & Cookies Statement?
The Sites contain links and references to other websites administered by unaffiliated third parties. This Privacy & Cookies Statement does not apply to such third-party Sites. When you click a link to visit a third-party website, you will be subject to that website’s privacy practices. We encourage you to familiarize yourself with the privacy and security practices of the linked third-party website before providing any Personal Data on those websites.
(vii) How will we handle any changes to this Privacy & Cookies Statement?
We may update this Privacy & Cookies Statement from time to time as our services and privacy practices change, or as required by law. The effective date of our Privacy & Cookies Statement is posted below, and we encourage you to visit our Sites periodically to stay informed about our privacy practices. We will post the updated version of the Privacy & Cookies Statement on our Sites and ask for your consent to the changes if legally required.
If you have questions or comments regarding this Privacy & Cookies Statement or our privacy practices, please contact us at Corp_General_Counsel@hallstar.com. You may also have a right to lodge a complaint with a supervisory authority.
Effective Date: October 5, 2018