Data Protection Notice of SUNSTAR Americas, Inc

Last updated on July 1st 2023

If you want to know more, please read our full Privacy Policy below:

1.    What this privacy policy covers

This Privacy Policy applies to personal information collected through:

Our “Services”

• Websites located at the domain sunstargum.com and professional.sunstargum.com (the "Websites”).
• Email, telephone, and other electronic messages between you and us.
• Workshops, demonstrations, tradeshows, conferences, and other events.
• Promotions, surveys, sweepstakes/contest entries, and when you otherwise voluntarily provide us information.
• Marketing research and social media platforms.

This Privacy Policy does not apply to personal information collected by:

Parties other than Sunstar

• Including any third party, through any website, application, or content (such as advertising), that may link to or be accessible from or on the Websites.

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2.    Data Controller, Data Protection Officer, and Representative

Sunstar is the data controller of the Personal Data (as defined by the EU General Data Protection Regulation (“GDPR”) or its successor) you provide through the Services. Our Data Protection Representative / Privacy Officer may be contacted at:

SUNSTAR Suisse SA
Route de Pallatex 15
1163 Etoy
Switzerland

privacy@ch.sunstar.com

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3.    Information Collection

Sunstar collects the following categories of personal information, including in the preceding twelve months, when you provide it directly to us and when you use the Services. This information includes both personally identifiable information and information which does not directly identify you:

• Browsing Information
• Traffic and Location Information
• Comment and Opinion Information
• Commercial Information
• Contact Information
• Financial Information
• Sensory and Electronic Information
• Social Media Data
• User Account Information

Sensitive Information

• In some circumstances, Sunstar collects, uses, and processes personal information which is classified as sensitive information under applicable data protection and privacy laws.
• The categories of sensitive information we collect includes location information.

We may also collect non-personally identifiable, aggregated information

• We may collect aggregated information, such as Website usage data. 
• This data is collected in the aggregate only but may include or be combined with other user information that users have voluntarily submitted.
• We commit to maintain and use data only in a de-identified, aggregate form and not attempt to re-identify this data.

When do we collect personal information?

• We collect this information when you take certain actions like interacting with our Services, submitting a form to contact us, creating an account with us, and becoming one of our vendors or customers.
• We collect information automatically when you browse our Websites.
• Sunstar collects information when we interact with customers and vendors at events, tradeshows, conferences, or through contests.

How long do we keep personal information?

• Sunstar uses several criteria to determine how long we should keep categories of personal information.
• We keep data until you close or deactivate your account, until we no longer have a business purpose for the data, or until we no longer have an obligation to keep it, under law or otherwise.
• Please understand that residual copies of the personal information can be stored in locations or formats that make complete erasure extremely difficult.
• The best way to ensure you control your information is to give us only the personal information that you are completely comfortable sharing with us.

The following categories of personal data are processed:

• Browsing Information:  we colleect browsing information automatically when you visit our websites. Examples of specific data include: 
  •  IP address
  • Browser Type
  • Browser Settings
  • Device ID
  • Operating System
  • Cookie ID
  • Location Information
  • Browsing behavior information
• Comment and Opinion Information:  we collect comment and opinion information when you interact with our chat features or call our customer service department. Examples of specific data include: 
  • Chat logs
  • Comments
  • Ratings
  • Reviews
  • Survey Reponses
• Commercial Information:  we collect commercial information when you become our customer or vendor. Examples of specific data include: 
  • Business address
  • Business phone number
• Contact Information:  we collect contact information when you create an account on our Websites or use our Websites to contact us. Examples of specific data include: 
  • Name
  • Contact details
  • Postal address
  • Personal email
  • Phone numbers
  • Previous residence address
• Financial Information:  we collect financial information when you place an order with us. Examples of specific data include: 
  • Bank account information
  • Payment card information
• Sensory and Electronic Information:  we collect sensory and electronic information automatically when you visit our facilities. Examples of specific data include: 
  • CCTV Recordings
• Social Media Information:  we collect this information automatically when you share information through social media widgets on our Websites. We also collect it when you voluntarily provide it to us. Examples of specific data include: 
  • Profile username
  • First name
  • Last name
  • Contact information
  • Profile picture
  • Post history
• User Account Information:  we generate or collect this information when you voluntarily create an account on our Websites or with our sales department. Examples of specific data include: 
  • Account username or identifier
  • Account password

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4.    Sources of Information

Sunstar collects information from a variety of sources, including:

You

• When you provide such information directly to us.
  • When you create an account or use our interactive tools and Services.
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
  • When you order Sunstar email newsletters.
• When you use the Services and such information is collected automatically
  • Through cookies and other tracking technology.
  • If you use a location-enabled browser, we may receive information about your location and device, as applicable.

Third Parties

• Vendors
  • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
  • We may use vendors to obtain information to generate leads and create user profiles.
• Advertising Partners
  • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our Websites, products, Services, advertisements or communications.
• Data Brokers
  • We receive mailing lists, for example, when we purchase it from suppliers and retailers of datasets.
• Social Networks
  • If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

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5.    How we use the Information we Collect

Sunstar uses personal information for a variety of business purposes. When you share personal information with us, we may use it for several purposes. For example, we may use the information we obtain about you to:

Provide, Customize, and Improve the Services

• Creating and managing your account.
• Processing orders or other transactions; billing.
• Providing you with the products, Services, or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, Websites content, and communications based on your preferences.
• Performing fraud prevention, security, and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.

Market the Services

• Marketing and selling the Services.
• Advertising our products and Services; measuring and improving the effectiveness of advertisements.

Correspond with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Sunstar or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you including reports, new features and promotional offers.

Meet Legal Requirements and Enforce Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• For any mergers, acquisitions, or transfers of corporate assets.
• Protecting the rights, property, or safety of you, Sunstar, or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

Sunstar processes personal information by relying on several legal bases. If GDPR applies to the processing of your personal information, we process your information for the purposes described in this Privacy Policy, based on the following legal grounds:

When we’re providing a product or service

• We process your data to provide and support a product or service you’ve asked for under a contract, including but not limited to delivering our Terms of Service.

When we’re pursuing our legitimate interests

• We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means we process your information for things like:
  • offering and improving our Products and Services.
  • developing new products and features.
  • understanding how our Products and Services are used.
  • performing research that improves our Products and Services for our users.
  • sending you direct marketing and other communications.
  • detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our Services.
  • maintaining and improving the integrity of our computing systems, and protecting our users’ data security.
  • enforcing legal claims, including investigation of potential violations of applicable Terms of Service.

When we have a legal obligation

• For example, if we’re responding to a legal process or an enforceable governmental request.

When you have provided your consent

• We ask for your consent to process your personal information for certain specific purposes.
• You have the right to withdraw that consent at any time.

We process your personal data for the following purposes:

• Purpose:  process, validate, and deliver your purchases
  • Information Categories Processed for Purpose:  
    • Commercial
    • Contact
    • Financial
  • Information Categories Disclosed to Third Parties for Purpose: 
    • Commercial
    • Contact
    • Financial
  • Categories of Third Parties to Whom Info is Disclosed
    • Service Providers and Advisors
  • Information Processed for Targeted Advertising? 
    • Yes
• Purpose:  Create content most relevant to you
  • Information Categories Processed for Purpose: 
    • Browsing
    • Comment and Opinion
  • Information Categories Disclosed to Third Parties for Purpose
    • Browsing
  • Categories of Third Parties to Whom Info is Disclosed: 
    • Service Providers
    • Select third parties
  • Information Processed for Targeted Advertising? 
    • Yes

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6.    How We Disclose Information to Others

Selling and Sharing.

• Sunstar does not sell your personal information
  • Nor have we done so in the last twelve months.
  • By ‘sell,’ we mean exchanging your data with another party for financial compensation.

• We do share your anonymized information
  • By ‘share,’ we mean making - usage personal information available to another party for cross-site or interest-based advertising. 
  • Sunstar shares website usage information about visitors to the Websites with a reputable third party for the purpose of targeting our Internet banner advertisements on the Websites and other sites. To do this, we use cookies and pixel tags provided by our third-party ad server on the Websites. The information we collect and share through this technology is not personally identifiable. The use of advertising cookies and pixel tags sent by such third-party web servers is standard in the internet industry.
  • We share information with analytics service providers, such as Google.
  • Those parties may combine your browsing information, including information from your use of our Websites, to generate interest-based advertisements.

We disclose your information to parties we work with.

Product and Service Providers: These parties help us provide the Services or perform business functions on our behalf. They are required by contract or law to only use or disclose the information as necessary to perform the business function on our behalf or as otherwise required by law. They include:

• Hosting, technology and communication providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Product fulfillment and delivery providers.
• Payment processors.
  • Our payment processing partner Chase collects your voluntarily-provided payment card information necessary to process your payment.
  • Please see Chase’s terms of service and privacy policy for information on its use and storage of your Personal Data.

Analytics Partners: These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

Parties You Authorize, Access, or Authenticate

• Third parties you access through the services.
• Social media services.
• Other users.

We disclose information under other circumstances and to other parties.

When you consent

• Out of respect for your privacy, Sunstar will not disclose your personal information to others without your consent, except as specified in this Privacy Policy.

To our affiliates and companies in the same group of companies as us

• Our affiliates and subsidiaries (i.e., any organization or brand we own or control) or our ultimate holding company Sunstar. (i.e., any organization that owns or controls us) and any subsidiaries it owns.
• We disclose the personal information that we collect to other Sunstar companies, subsidiaries, and related affiliates.
• These companies may use your personal information in the same way as we can under this Privacy Policy.

To the public

• When you provide feedback, reviews, or post user content on our Websites.
• For example, if you post a product review on our Websites or a comment on our social media sites, your personal information, such as your first name, last initial, state of residence, or your comments, on our social media pages.

To purchasers and third parties in connection with a business transaction

• Personal information may be disclosed to third parties in connection with a Sunstar-related transaction, such as a merger, sale of Sunstar assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business by Sunstar or a third party, or in the event of a bankruptcy or related or similar proceedings.

When law enforcement, regulators, and other parties request information for legal reasons

• We may provide personal information without your consent to third parties as required by law or subpoena or if we reasonably believe that such action is necessary to:
  • Comply with the law and the reasonable requests of law enforcement;
  • To enforce our Terms of Use or to protect the security or integrity of our Service; and/or
  • To exercise or protect the rights, property, or personal safety of Sunstar, our visitors, or others.

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7.    Your Privacy Rights

Certain laws like the California Privacy Rights Act, the Virginia Consumer Data Protection Act, and the Colorado Privacy Act, and Canada’s Personal Information Protection and Electronic Documents Act, among others, grant you rights to control your personal information. Consistent with these laws, Sunstar gives you options to access, edit, or remove certain information, as well as choices about how we contact you. Although some of these rights apply generally, certain rights will only apply to limited individuals or circumstances.

Right to Know and Access Information

• Note that much of the information you are entitled to know or access is disclosed in this Privacy Notice.
• With this said, you have the right to know about our information practices.
• You also have the right to access the categories of data we collect, with whom we share that information, and, in some cases, what specific personal information we associate with you or your account.

Right to Data Portability

• If you request a copy of specific information we have about you then we will provide it in an easily accessible format.

Right to Deletion or Erasure

• You may request that we delete the personal information we have collected about you.
• Depending on the applicable law, in some cases we are required or permitted to retain that information, even if you validly requested we delete or erase it.

Right to Correct Information

• You may request we correct or rectify inaccurate information we associate with you or your account.

Right to Object to & Restrict Processing

• You may object to the processing of your personal information on the basis of our legitimate interests at any point in time.
• You may object to (and opt-out of) direct marketing. Please see the Universal Opt-Out right below.
• You may restrict or limit the way we use your information when:
  • You contest the accuracy of the personal information.
  • You believe our processing to be unlawful, but don’t want us to delete it.
  • We no longer need the personal information for the purposes we collected it, but must retain it for legal purposes (for example, defending legal claims).
  • You have objected to our processing of your personal information and we are verifying whether that objection controls our legitimate use of the personal information.

Right to Universal Opt Out

• You may limit certain ways we use and disclose your personal information (also called “opting-out” or a “request to opt out”). You may opt-out of:
  • The sharing of your personal information for targeted advertising purposes.
  • The disclosure of your sensitive personal information.

Right to Withdraw Consent

• You may withdraw your consent to our data privacy practices at any time.

Right to Non-Discrimination

• You have the right to not experience discrimination from us for exercising the rights listed in this section.
• What we mean by discrimination is denying you access to our Services or limiting the quality of our services.
• However, limiting use of, or deleting, your personal information may restrict the purposes or uses that rely on that information.
• If you need further assistance, you can contact Sunstar through one of the channels listed below under “Contact.”

Other California Rights

• California’s Shine the Light Law
  • If you are a California resident, you may request and obtain information regarding our disclosure of your personal information to third parties for their direct marketing purposes in the preceding year.
  • If applicable, this information would include a list of the categories of personal information shared and the names and addresses of those third parties with which we shared your information in the immediately preceding year.
• California’s Online Eraser Law
  • If you are a California resident who is under 18 years old and are a registered user of our Websites, you may request and obtain removal of content or information that you have posted.
  • A request to remove content or information posted by you does not ensure or require complete or comprehensive removal of such content or information from our databases (for example, content that has been reposted by another user may not be removable).

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8.    Exercising Your Rights

To exercise any of your privacy rights, contact:

SUNSTAR Suisse SA
Route de Pallatex 15
1163 Etoy
Switzerland

privacy@ch.sunstar.com

Help us process your request by including these details:

• Please include your email address, full name, and your specific information about your request(s) and, if applicable, specifically what information you do not want to receive.
• If you would like to update or correct your name, email address, street address, or other personal information with us, please include specific details about the information you wish to have updated or corrected.
• If you are appealing a decision please provide information about the denied request.

Sunstar’s process to fulfil a privacy rights request:

First, we acknowledge your request

• Sunstar will first send you a message acknowledging receipt of your request within 10 days.

Next, we ensure that you are the person making the request

• In general, when you make a request Sunstar will take steps to verify your identity.
• Verification steps may include asking you for personal information, such as your name, address, or other information we maintain about you.
• If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of the denial.

Finally, we provide a response

• We will either honor your request or tell you why we denied it.

Your agent can submit requests for you

• You may also designate an authorized agent to submit requests on your behalf.
• If you do so, you will be required to verify your identity by providing us with certain personal information as described above.
• Additionally, we will also require written proof the agent has permission to act on your behalf.
• We will deny your request if the agent is unable to submit proof to us that you have authorized them to act on your behalf.

How long will it take?

• Sunstar will either fulfill or reject your request as soon as we can, generally within 30 days from when we receive your request (or less, if required by law).
• But we may be allowed to take longer to process your request under certain circumstances.
• We will let you know if we expect your request will take us longer than normal to fulfill.

What if my request is denied?

• You may appeal the denial if you feel we have made a mistake.
• To submit an appeal please use the same method of contact listed above.

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9.    Your Privacy Choices

Messaging and newsletter communications.

• You may control how you receive certain types of communications by unsubscribing within the body of the communication.
• Note that some messages are required, service-related messages like transaction confirmation messages, legal notices, or updates.
• If you no longer wish to use our Services or our Websites, or receive optional communications then you may submit requests to delete your account and your personal information.

Cookies and web tracking technologies.

What we use on the Services

• We use cookies and other embedded tracking technology like web beacons, and pixels which automatically collect users’ browsing information when they use our Websites.

Third-Party Cookies

• You will find other parties’ trackers on our Websites. Other parties like our analytics and advertising partners place code with cookies or web beacons embedded in them. Some third-party cookies are used to track a particular user’s activity across the Internet.
• The use of advertising cookies and pixel tags sent by such third-party web servers is standard in the internet industry.

Limiting Google’s Tracking and Data Collection Through Cookies

• You may limit the automatic collection of information by Google, including the collection of personal information about your online activities over time and across third-party websites or online services, by opting-out of such collection. Download the opt-out browser extension, located here, to opt-out of the automatic collection of browsing and device data.

Opt out of cross-site and interest-based advertising.

First, this is not a universal opt out request you submit to us

• Submitting a request to opt out of cross-site advertising using the methods below is not the same as opting out of the way we use your personal information.
• Sunstar does not receive your opt out of cross-site advertising.

What happens when I opt out of cross-site advertising?

• When you opt out, your selection is stored on a cookie on your device. 
• If you delete the cookie from that device or sign in from a different device, you will need to opt out again.

Does opting out of cross-site advertising stop all data collection?

• Because the data used for interest-based advertising is also used for other necessary purposes (including providing our Services, for authentication, and security purposes), opting out of interest-based advertising does not stop the data from being collected nor reduce the number of advertisements you will see.
• However, the data will not be used for interest-based advertising, which means the advertisements you do see may be less relevant to you.

Is my mobile device included when I opt out of cross-site advertising?

• When using a mobile application, you may receive interest-based in-application advertisements.
• Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your device.
• In addition, each operating system (e.g., iOS for Apple devices, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of interest-based in-application advertisements.
• You may review the support materials and/or the privacy settings for the respective operating system in order to opt-out of interest-based in-application advertisements.
• For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.

Limit the automatic collection of information by any participating third-party advertisers

• To submit your request to opt-out of that automatic collection of browsing data, visit:
  • The Digital Advertising Alliance page, or 
  • The Network Advertising Initiative page

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10.     Location of Processing

Your personal information may be transferred to and processed by the recipients indicated in “How We Disclose Information to Others” section of this Privacy Policy. Some of these recipients may be located in a country outside the one where you reside, and which may not offer similar levels of data protection by law.

Those parties may be located both within and outside the European Union or European Economic Area, the United Kingdom, or Switzerland.

When your information is moved from your home country to another country, the laws and rules that protect your personal data in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal data may vary from country to country. In particular, if your information is in the United States, it may be accessed by government authorities in accordance with U.S. law.

Please be advised that information Sunstar collects about you via the Services may be transferred, processed and/or accessed by us in the United States, or another country where we, or our service providers operate. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal data, may differ from those that apply in the country in which you reside. If you are located outside the United States and choose to allow us to collect information about you, please be aware that Sunstar may transfer your personal data to the United States and process and store it there. We will transfer personal data only to those countries to which we are permitted by law to transfer personal data.

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11.     Third-Party Websites

This Privacy Notice applies only to Sunstar’s Services, including our Websites.

• Our Services may contain links to other websites including those that permit online transactions.
• We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other third parties we link to from our Websites.
• Sunstar does not endorse, approve, or certify these other websites, and we do not guarantee the accuracy, completeness, efficacy, or timeliness of the information contained on those websites.
• You should check the applicable privacy policy of the website sponsor when linking to other websites.

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12.     Security and Your Account

Sunstar will take steps to protect your personal information that you transmit to us and to protect such information from loss or misuse, and unauthorized access, disclosure, alteration or destruction. However, no internet transmission is ever fully secure, and we cannot guarantee that information transmitted via our Websites will remain confidential at all times. When we collect information, it is stored in an area to which the general public does not have access. We maintain industry-standard physical, electronic and procedural safeguards to ensure that personal information is stored and processed responsibly.

In the event that any use of the Websites involve log-in credentials, please bear in mind that anyone you provide with your log-in information will also have access to your account and personal information. If you use our Websites, you are responsible for maintaining the confidentiality of any log-in credentials associated with the Websites.

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13.     Users of our Websites Under the Age of 13

You must be at least 13 to use our Services. Sunstar takes children’s privacy seriously. Sunstar does not have actual knowledge of any personal information about individuals under the age of 13 whose information has been collected through our Services. If we become aware that a person submitting information to us through any part of our Services not 13, we delete the information as soon as we discover it and do not use it for any purpose nor disclose it to third parties.

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14.     Changes to Privacy Policy

We reserve the right to change this Privacy Policy from time to time by posting revisions on our Websites. Sunstar will update the effective date of this Privacy Policy when changes are made.

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15.    Contact Us

You may contact us with any inquiries related to our use of your personal information disclosed in this Privacy Policy or to exercise your privacy rights by:

SUNSTAR Suisse SA
Route de Pallatex 15
1163 Etoy
Switzerland

privacy@ch.sunstar.com

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