Last Updated: November 1, 2020
1. Commitment to Your Privacy
Clayman & Associates (“Clayman & Associates”, “we”, “us” or “our”) respects your preferences about the processing of your Personal Data. We provide this Privacy Notice so you understand how we process your Personal Data, how you can control its use and how you can exercise your privacy rights. It also describes our practices regarding information collected from the Clayman & Associates website that link or refer to this Notice (such as our websites, computer or mobile software applications, social media pages and HTML-formatted e-mail messages) (“Sites”), as well as through offline sales and marketing activities (together with the Sites, the “Information Channels”).
Please read this Privacy Notice. By using or visiting the Services, you acknowledge the terms of this Privacy Notice. Use of our Services is voluntary. If you do not agree to the provisions Privacy Notice, you must immediately cease such use.
2. The Personal Data We Collect
There are a few places, both online and offline, where Clayman & Associates gives you an opportunity to voluntarily provide us with information that directly or indirectly identifies you (your “Personal Data”). Through your interaction with and use of the Information Channels, such as ordering or inquiring about a product or service, applying for a job, sending feedback, visiting our site and other interactions, we may ask you to provide Personal Data such as your first and last name, mailing address, email address, telephone number, credit card number, IP address, invoice and shipping addresses, job title, organization type, invoice history, details of conversations that you may have had with us regarding your purchase questions and experiences, details regarding your products or services purchased and other information. For our entertainment, hospitality and food and beverage businesses, information such as relevant dietary information, time/date of arrival and departure, flight details and driver’s license number may also be requested to better accommodate your customer experiences with those businesses.
You choose whether to engage in these activities. Depending upon the activity, some of the information Clayman & Associates asks you to provide is identified as mandatory and some is voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
In addition to the information you choose to provide, we may automatically collect other information about you through the Sites. Such information may include, without limitation: the unique device identifier of your mobile device, mobile network information, the model and serial number and telephone number of your mobile device, information regarding your access to and use of an App, the pages you visit and the time of your visits, your operating system, browser type, the domain name of your internet service provider, and your Internet Protocol (IP) address. We may combine any of the information we collect from or about you and use it in the manner described in this Privacy Notice. For example, Clayman & Associates may use your IP address, together with other Personal Data that you may provide, such as your email address, to communicate with you directly about products and services that Clayman & Associates believes may be of interest based on your activity on the Sites. We may also use your account data and prior purchase and service histories.
Clayman & Associates also may collect information about you from publicly available sources, or from third parties such as our channel partners or credit reference agencies in connection with your purchases. We may receive information about your interaction with us and use of our Services through a third-party social networking service.
Except as otherwise stated in this Notice, your IP address, cookies and other technologies (as more particularly described below) are generally used by Clayman & Associates on an anonymous basis (i.e. without directly referring to you by name), among other things to (1) help diagnose problems with Clayman & Associates’s server, administer the Services, measure the use of the Services, improve the content of the Services; (2) to identify visitors’ domain names, the type of web browsers used, the pages viewed, the websites from which a visitor found this Services, the websites to which a visitor went after leaving the Services; the search terms and search engines used to find this Services; and (3) to gather other web analytics information relating to visitors’ use and navigation of the Services. We will comply with applicable laws regarding our use and processing of your data.
3. Cookies and Other Technologies
Like many companies, Clayman & Associates uses “cookies” and other similar tracking technology (collectively “Cookies”). Our server will query your browser to see if there are Cookies previously set by our electronic Information Channels.
A cookie is a small text file which is placed on your device. Cookies help to analyze web traffic and allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Certain cookies may contain Personal Data – for example, if you click “Remember me” when logging in, a cookie may store your username. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information and general usage and volume statistical information. Cookies may also be used to collect individualized website use data, provide electronic Information Channel personalization or conduct and measure the effectiveness of advertising in accordance with this Notice.
Cookies set by the website owner (in this case, Clayman & Associates) are called “first-party cookies”. Cookies set by parties other than the website owner are called “third-party cookies.” Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.
We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Information Channels to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Information Channels. Third parties serve cookies through our Information Channels for advertising, analytics and other purposes.
We may place cookies or similar files on your device for security purposes, to tell us whether you have visited the Information Channels before, to remember your language preferences, to determine if you are new visitor or to otherwise facilitate site navigation, and to personalize your experience on our Information Channels. Cookies allow us to collect technical and navigational information, such as browser type, time spent on our Information Channels and pages visited. Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them to you. Cookies may enhance your online experience by saving your preferences while you are visiting a website.
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to a website. We may use other similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphic files that contain a unique identifier that enable us to recognize when someone has visited our websites or opened an email we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our websites to another, to deliver or communicate with cookies, to understand whether you have come to our websites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their function.
How can you manage your cookies?
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that if you disable or reject cookies, some features and services may not work properly because we may not be able to recognize and associate you with your Eaton Account(s). In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.
4. Advertising technologies and networks
Clayman & Associates may also use third parties such as Google, Facebook, LinkedIn and Twitter and other programmatic advertising platforms to administer Clayman & Associates advertisements on third-party electronic channels. Personal Data, such as user community or implied or inferred interests, may be used in the selection of advertising to make sure that it has relevance to the user. Some ads may contain embedded pixels that may write and read cookies or return session connection information that allows advertisers to better determine how many individual users have interacted with the ad.
Clayman & Associates may also use advertising technologies and participate in advertising technology networks that collect usage information from Clayman & Associates and non-Clayman & Associates websites, as well as from other sources, to show you Clayman & Associates-related advertisements on Clayman & Associates’ own and third-party websites. These advertisements may be tailored to your perceived interests using retargeting and behavioral advertising technologies. Any retargeted or behavioral advertisements served to your browser will contain information on or near it that informs you about the advertising technology partner and how to opt-out of viewing such advertisements. Opting-out does not mean that you will stop receiving ads from us. It means that you still stop receiving ads from Clayman & Associates that have been targeted to you based on your visits and browsing activity across websites over time.
Cookie-based tools that allow you to opt-out of Interest-Based Advertising prevent Clayman & Associates and other participating advertising technology companies from serving interest-related ads to you on behalf of Clayman & Associates. They will only work on the internet browser on which they are deposited, and they will function only if your browser is set to accept third-party cookies. These cookie-based opt-out tools may not be as reliable where (e.g., certain mobile devices and operating systems) cookies are sometimes automatically disabled or removed. If you delete cookies, change browsers, computers or use another operating system, you will need to opt-out again.
5. Legal basis for processing Personal Data
Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
We will normally collect Personal Data from you only (i) where we have your consent to do so (ii) where we need the Personal Data to perform a contract with you, or (iii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
6. European Residents: Right to Opt-out
To comply with legislation in the European Union, European Economic Area, Switzerland and the UK, Clayman & Associates asks for your consent to set the cookies described above. When you arrive on the Site, a banner informing you of the types of cookies we use will appear. By clicking ‘continue’ you expressly consent to the use of such cookies. Once your consent has been provided, this message will not appear again when you revisit. If you do not click “continue,” your continued use of the Site will indicate your implied consent. The banner will remain, and we will set only the cookies for which implied consent is sufficient. If you, or another user of your computer, wish to withdraw your consent at any time, you can do so by altering your browser settings or by selecting the opt-out options above. In some instances, when you opt-out, a new cookie (Opt-Out-Cookie) is placed in your web browser. This tells the third party provider to cease data collection from your browser and prevents advertisements from being delivered to you.
If you would like us to stop sending you marketing emails, we encourage you to use the opt-out link at the bottom of any marketing email we send. You may also contact us at email@example.com.
7. The Way Clayman & Associates Uses Personal Data
Clayman & Associates may use your information for business purposes in accordance with the law for particular activities, including, without limitation:
- to provide the Services to you, including any updates, service communications and notifications, including push notifications sent through an App in accordance with your settings;
- to manage and administer your user profile or registered account;
- to enable our suppliers, channel partners and service providers to carry out certain functions on our behalf, including the hosting of our websites, apps and booking platforms, verification, technical, logistical or other functions, and to provide local sales and service support for our products;
- to allow you to participate in surveys and similar activities;
- to process and respond to your inquiries, orders, comments, complaints and requests;
- to send you information about your relationship or transactions with us;
- to verify your identity, where required;
- to process a job application that you may make to us, manage your login details on our careers platforms and use recruitment tools that allow us to assess our applicants suitability for specific roles;
- to allow us to personalize and enhance your experience using the Services. For these purposes we may create a profile about you, which will also enable us to increase our communication relevance;
- to contact you with information, that we believe will be of interest to you, done either by us or a third-party source, as permitted by law and, where applicable, subject to your consent;
- to improve the Services, to develop new products and services and for research that we or a third party may perform regarding the Services;
- to create anonymous data, which may be used for legitimate business purposes;
- to generate and review reports and data about our user base and service usage patterns, and to analyze the accuracy, effectiveness, usability or popularity of the Services;
- to prevent fraudulent transactions, monitor against theft and otherwise protect our users and our business; to ensure the security of your user account, our premises and facilities and our business, for example, by monitoring account activity [and deploying CCTV];
- to administer technical aspects and troubleshoot the Services; and
- to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law, or to comply with financial reporting requirements.
[For EU Residents: where we process Personal Data about you, the legal basis for our processing for the purposes described in Section 6 above will typically include:
- processing necessary to fulfil a contract, such as our terms and conditions, that we have in place with you, such as the processing for the purposes set out in paragraphs a), b), c), d) and e) above;
- processing necessary for our or a third party’s legitimate interests, such as the processing for the purposes set out in paragraphs a), c), d), e), f), g), h), i), j), k), l), m) and n) above, which is carried out on the basis of our legitimate interests to ensure that our Services are competitive and provided efficiently, without delays and in an user-friendly and personalized manner taking into account user feedback, data and profiles, to ensure the security of our business and information of our users, and to ensure the proper and efficient administration of our business, unless consent is required for any such processing under applicable law;
- your consent, such as the processing for the purposes set out in paragraphs i) and j) above, where such consent is required under applicable law;
- processing necessary for compliance with a legal obligation to which we are subject, such as the processing for the purposes set out in paragraph p) above; and
- other applicable legal grounds for processing from time to time.]
6. The Way Clayman & Associates May Disclose Information
Clayman & Associates may share information about you for the purposes listed above and in accordance with applicable law with:
- Clayman & Associates’ subsidiaries and affiliates and business units worldwide;
- distributors, dealers or other business partners in connection with the Services as permitted by law, and where required by law, subject to your consent. These parties will process information needed to perform their functions and in accordance with our agreements with them. Clayman & Associates’ affiliates, distributors, dealers or other business partners may use this information for marketing and solicitation purposes.
- our outsourced service providers, vendors and consultants, such as merchant services providers, IT consultants, incident response and business continuity vendors;
- credit card authorization service providers and the credit card-issuing bank to confirm and settle payment for products or services purchased on the Services and to facilitate returns or refunds;
- our marketing, communications and advertising partners;
- [public where you have included information in our blogs, forums and discussion groups;]
- Clayman & Associates may share aggregated anonymous information relating to visitors to and users of the Services with affiliated or unaffiliated third parties;
- legal entities, on a temporary or permanent basis, in connection with a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction, or if the ownership of all or substantially all of our business otherwise changes;
- the relevant parties (1) in response to a subpoena, search warrant, court order, or other legal process or request, or as may otherwise be required by applicable law or regulation; (2) to protect and defend Clayman & Associates’ rights or property or those of its affiliates, distributors, dealers, business partners, or others; or (3) as Clayman & Associates, in its sole discretion, believes is appropriate under exigent circumstances in response to a perceived threat to the personal safety or property of any person or organization; and
- any other third party where you have provided your consent, if such consent is required.
8. Processing of your Personal Data
The Sites are currently hosted on servers located within the United States, but the locations of Clayman & Associates’ servers may change from time-to-time. Your Personal Data may be stored on servers located within the United States, or in another country. In addition, Clayman & Associates may transfer your Personal Data to affiliates, distributors, dealers, business partners, or others located in the United States or other countries in accordance with, and for the purposes as described in, this Privacy Notice.
In these circumstances, Clayman & Associates will ensure that your Personal Data is adequately protected, as required by law. [If you are located in the European Union, European Economic Area, Switzerland or the UK you may contact us at firstname.lastname@example.org or the address below for information regarding the relevant the safeguards which we have put in place to protect your Personal Data.]
9. Retention of your Personal Data
Clayman & Associates keeps your Personal Data as long as we need it for the purposes for which it was originally collected (or to which you have subsequently consented), for other legitimate purposes (such as regulatory compliance), or as otherwise required or permitted by applicable law. [If you are located in the European Economic Area, Switzerland or the UK, you may contact us about further detail about our data retention periods in relation to your Personal Data.]
10. Clayman & Associates’s Relationship to other Sites or Mobile Applications that can be Accessed through the Services
11. Other Information You should know about your Privacy
Clayman & Associates’s Services are not intended for children under the age of 18. If you are under the age of 18, please do not use or submit any Personal Data to us. If you have reason to believe that we may have accidentally received Personal Data from an individual under age 18, please contact us immediately at email@example.com.
12. Access & Correction of your Personal Data
Clayman & Associates strives to maintain the accuracy and integrity of the Personal Data in its databases and to keep that information up-to-date. If you would like to review or correct your Personal Data, please contact Clayman & Associates by email at firstname.lastname@example.org or send a letter to:
Clayman & Associates
27811 State Route 7
Marietta, Ohio 45750
All communications must be in the English language.
Clayman & Associates will respond to reasonable requests within the time limits established by applicable law or within a reasonable time if no time limit is established by applicable law. For your protection, Clayman & Associates may ask you for additional information to verify your identity. In most cases, we will provide the access you request and correct or delete any inaccurate Personal Data you discover. Requests to delete Personal Data are subject to any applicable legal and ethical reporting or document retention obligations imposed on Clayman & Associates.
European Residents: If you are a resident of the European Union, European Economic Area, Switzerland or the UK, you have the right to review, correct, update, suppress, transfer, restrict or delete Personal Data that you have provided to us, subject to the conditions set forth in applicable law. You can make such a request by using this form or emailing us at email@example.com with “EU Resident Access Request” in the subject line. In your request, please tell us what Personal Data you would like to have changed, suppressed or limited. Please note that we may need to exclude certain information as part of your request, e.g. in order to protect the privacy of other individuals or if we are permitted to exclude the information for legal or other reasons. We prefer that you contact us directly about any questions or complaints in relation to how we process your Personal Data. However, you have the right to contact the relevant supervisory authority in Europe directly should you wish to do so.
13. Your California Privacy
The California Consumer Privacy Act of 2018 (“CCPA”) requires us to provide additional privacy-related information to residents of California.
The section entitled “The Personal Data We Collect” above lists the categories of Personal Data we have collected about California residents in the preceding 12 months. These categories of Personal Data correspond with the following categories of Personal Data provided under the CCPA:
- Identifiers including first and last name, mailing address, email address, telephone number, and IP address;
- Commercial information including credit card number and other information required to purchase our products and services;
- Internet or other electronic network activity information including the unique device identifier of your mobile device, mobile network information, the model and serial number of your mobile device, information regarding your access to and use of an App, the Site pages you visit and the time of your visits, your operating system, browser type, the domain name of your internet service provider;
- Location Information such as geolocation information from your mobile device;
- Audio, Electronic, Visual or Similar Information such as photos, video, service call recordings or facility camera footage;
- Professional or Employment-Related Information such as occupation, job title, or professional association membership information; and
- Inferences Drawn from Personal Information such as information about your preferences or likelihood to purchase our products or services.
As described in the section entitled “The Personal Data We Collect” above, we collect Personal Data from you (and the devices you use), from publicly available sources, or from third parties such as our channel partners, business partners or credit reference agencies in connection with your purchases.
The section entitled “The Way Clayman & Associates Uses Personal Data” above lists the business and commercial purposes for which we collect California residents’ Personal Data. The section entitled “The Way Clayman & Associates May Disclose Information,” describes the parties with whom we may share and/or disclose your Personal Data. Clayman & Associates generally obtains your express consent and direction for targeting cookies, and does not otherwise “sell” your personal data as defined by CCPA.
Sharing your Personal Data for business purposes: we may share the categories of your Personal Data described above with affiliates and business units; distributors, dealers, or other business partners; service providers, vendors, and consultants; and other third parties for our business purposes. As described above, examples of business purposes include, but are not limited to, providing the Services, managing and administering user profiles or registered accounts, and processing and responding to inquiries, orders, comments, applications, complaints and requests.
California Residents’ Privacy Rights
Subject to certain exceptions and qualifications, as a California resident, you have the right to request access to your Personal Data and request deletion of your Personal Data. California consumers also have the right to opt out of sales of personal data, if applicable. Should you wish to request the exercise of your rights with regard to your Personal Data, please complete this form or call us at 1-740-376-1470. We may need to request additional information from you, including to verify your identity. Please indicate in your request that you are a California resident making a “California privacy rights” inquiry.
14. Clayman & Associates’s Commitment to Security of Your Personal Data
Clayman & Associates has implemented appropriate physical, managerial and technical measures to protect the security of data and information and to ensure a level of security of Personal Data appropriate to the risks of a breach. Unless applicable law provides otherwise, Clayman & Associates does not guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data, including Personal Data. While Clayman & Associates strives to protect your data, we cannot always guarantee the security of any information you transmit to or from the Services, and you provide such information at your own risk. You acknowledge that: (1) there are security and privacy limitations in computer systems and on the Internet which are beyond Clayman & Associates’ control; and (2) any such information and data, including Personal Data, may be viewed or tampered with by a third party while such information or data is being used, transmitted, processed, or stored.
15. Changes to Privacy Notice
Clayman & Associates may change its Privacy Notice from time to time. This Privacy Notice was made effective on the date indicated above. Clayman & Associates encourages you to review this Privacy Notice regularly in your use of the Services and especially before you provide any information. Your continued interaction with us or your continued use of our Services will amount to your acknowledgement of the amended Privacy Notice.