Last modified: January 2, 2020
1. Acceptance
This document sets forth IMCO’s Privacy Policy (“Policy”), applicable to users of IMCO’s website (“Website”). By accessing the Website, the user acknowledges and accepts these terms and conditions. If a user has any questions about this Policy, the user should contact IMCO by email to support@imcousa.com or by writing to:
IMCO Privacy Policy
IMCO Carbide Tool Inc.
28170 Cedar Park Blvd.
Perrysburg, OH 43551
2. IMCO’s Commitment
IMCO understands users concern about privacy. This Policy tells users how IMCO uses and protects their personal information, and describes the choices users have concerning our use of their personal information. IMCO reserves the right to change this Policy from time to time in order to address new issues and reflect changes, and will post any changes here so that users always know what information IMCO gathers, how that information is used, and whether it will be disclosed to anyone.
3. Online Information Gathering and Purposes for Processing
Information collected online is often defined as being either personal information or anonymous information:
- Personal Information: Information which relates to an identified or identifiable individual (i.e., a natural person) and reveals the specifics of who they are, such as name, email address or postal address; it may also include their views and preferences as they relate to IMCO’s services.
- Anonymous Information: Cannot be tied back to a specific individual.
The information collected by IMCO includes:
Personal Information
The only way IMCO knows something about a user is when the user uses a personalized service, such as login to the Website, or voluntarily discloses the user’s information such as a credit card number, name, address, phone number, fax number, email address, government identification number, uploaded images, demographic, and other personal and financial information when the user register for membership with IMCO, transact business on the Website, communicates by sending IMCO an email, completes an IMCO survey, or completes a form.
The choice of how much user personal information is disclosed to IMCO is left up to the user.
In some cases, such as on discussion boards, blogs or other public forums, any personal information a user provides may become publicly available to other IMCO members and member organizations and possibly the general public. Users should be aware that when they voluntarily disclose such personal information (e.g., user name and email address as used in a signature line), that information can be collected and used by others and may result in unsolicited messages from other posters or parties.
Collection of IP addresses: When visiting any Internet site the user’s unique address, called an “IP address”, is recorded. The amount of information about users made available from their IP addresses varies greatly, for instance depending on how they are connected to the Internet. IMCO does not release any information about the collection of this address to any third parties.
Survey Information: Occasionally, IMCO conducts surveys to assist us in our strategic planning and development of our benefits and services. IMCO may engage third parties to do this on its behalf. Survey responses will only be shared with third parties, including the membership at large, in aggregate.
Communications with IMCO: If a user contacts IMCO with a query or complaint, IMCO may keep a record of any phone number or email address used as well as the correspondence and the period of time it took for us to deal with the query or request.
In addition to the purposes noted above, IMCO may process a user’s personal information for the following purposes:
- to provide users with the information and products and services that the user has requested and send users marketing materials;
- to authenticate users access to the Website;
- for system administration purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to distinguish a user from other users (for example to remember log-in details);
- to monitor a user’s use of the Website to improve the user experience and to ensure that content is presented in the most effective manner for the user and for the user’s device;
- to publish membership directories, membership lists and registration lists on the Website and in print and digital media
- to notify users of any changes to our services;
- to improve the safety and security of the Website; and
- to comply with applicable laws and regulations.
Anonymous Information
IMCO collects and archives basic logging for site statistics. These log files show the daily number of visitors to the Website, the daily requests IMCO receives for particular files, what server locations those requests come from, including from which countries, as well as the domain name of the server or browser accessing the Website. These aggregated statistics are primarily used internally to provide better service to IMCO members.
4. Legal basis for processing user’s personal information
IMCO will only process a user’s personal information where IMCO has a legal basis to do so. The legal basis will depend on the purposes for which IMCO has collected and use the personal information. In almost every case the legal basis will be one of the following:
- Consent: For example, where a user has consented to receive certain marketing from IMCO. Users can withdraw their consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email IMCO sends or emailing IMCO at support@imcousa.com.
- IMCO’s legitimate business interests: Where it is necessary for IMCO to understand our users, promote IMCO services and operate effectively as an organization, provided in each case that this is done in a legitimate way which does not unduly affect user’s privacy and other rights.
- Provision of products or services: Where a user has requested products or services from IMCO, IMCO needs to use user contact details and payment information in order to process the request.
- Responding to user inquiries: When a user makes an inquiry of IMCO, IMCO will need to use the user’s contact information to respond.
- Enforcement of IMCO’s terms of service: IMCO may need to use a user’s personal information to enforce our Website terms of service and other user agreements.
- Compliance with law: Where IMCO is subject to a legal obligation and need to use a user’s personal information in order to comply with that obligation.
5. Non-Disclosure What about our Reps? “Third party companies” that represent and sell our line, but work for their own independent rep agency.
IMCO will not share a user’s personal information with any third parties except where:
- The user has consented or asked us to share user’s information with third parties;
- IMCO, or substantially all our IMCO’s assets are merged or acquired by a third party, in which case user’s personal information may form part of the transferred or merged assets;
- To provide anonymous statistical information about users of the Website and related usage information to reputable third parties;
- IMCO is using a reputable third party service provider to provide services that involve data processing, or;
- Where it is otherwise permitted by applicable law, or where IMCO is required by law to do so.
6. Where IMCO stores user personal information
The personal information that IMCO collects may be transferred to, and stored at, and processed in the United States, where privacy laws may be less stringent than the laws in a user’s country and where the government, courts, or law enforcement may be able to access user data. By submitting Personal Data to us, the user agrees to the transfer, storage and processing of the user’s Personal Data in the United States.
If a user is located in the European Economic Area (the “EEA”), including the UK, the following text shall apply: The personal information that IMCO collects may be transferred to, and stored at, a destination outside the EEA. Whenever IMCO transfers user information outside of the EEA, IMCO will take steps to ensure that appropriate safeguards are in place to protect the user’s personal information and to treat it in accordance with this Privacy Policy. In these cases, IMCO will rely on approved data transfer mechanisms (such as the EU “Standard Contractual Clauses” and the EU-US “Privacy Shield”) to ensure user information is subject to adequate safeguards in the recipient country. A user may contact IMCO for a copy of the safeguards which IMCO has put in place to protect user personal information and privacy rights in these circumstances.
7. How IMCO keeps user personal information
IMCO takes reasonable steps to ensure that the personal information that users provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised. IMCO may also keep a record of correspondence with users (for example if a user has made a complaint) for as long as is necessary to protect IMCO from a legal claim.
Where IMCO has collected the personal information based on user’s consent and IMCO has no other lawful basis to continue with that processing, if the user subsequently withdraws the user’s consent, IMCO will delete the personal information.However, where a user unsubscribes from marketing communications, IMCO will keep a record of the email address to ensure that marketing emails are not sent in the future.
8. User Rights
Applicable data protection may give certain rights in relation to usr’s personal information, including the right to object to and/or withdraw consent to the processing of user’s personal information, the right to access user’s personal information, and the ability to erase, restrict, or receive a machine-readable copy of user’s personal information. IMCO will handle any requests to exercise these rights in accordance with applicable law, and users can contact IMCO about user’s rights at any time by emailing us at support@imcousa.com.
Users have the right to lodge a complaint with a supervisory authority, in particular in the Member State of habitual residence, place of work, or place of the alleged infringement, if the user believes that the processing of the user’s personal data does not comply with legal requirements. If a user has such concerns IMCO requests that the user initially contact us (using the contact details above) so that IMCO can investigate, and hopefully resolve, IMCO’s concerns.
9. Cookies
To enable certain features that may be available or become available on the Website, our server will assign a user’s browser a unique identification number stored in a file on the user’s computer (a “cookie”, or similar technology). Cookies by themselves cannot be used to find out the identity of any user. This unique identification number will automatically identify the user’s browser to our computers whenever user interacts on the Website. Most browsers are initially set up to accept cookies, but can be reset to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Website may not function properly if the user disables cookies.
The types of information that IMCO may gather via cookies include the following:
- information about the user’s device, operating system and IP address;
- user’s login information;
- browser type and version;
- information about the visit, including URL, clickstream (i.e. user’s journey to, through and from our site), length of visits to certain pages, and page interaction information.
User’s do not have to accept cookies, but many features and functions of the Website may not be available if the user does not accept cookies.
10. Links
Users may find links to other sites or services on the Website. IMCO does not control the content or links that appear on these sites. In addition, these sites or services, including their contents and links, may be constantly changing. The fact that IMCO has made these links available to users is not an endorsement or recommendation by IMCO. IMCO provide these links only as a convenience.
Other companies linked to the Website may collect information about users who view or click on these sites. IMCO cannot control this collection of information. Users should contact these content providers directly if they have any questions about their use of the information they collect. These sites and services may have their own privacy policies, or no policy at all. IMCO encourage users to review the privacy policies of any third party sites or services before providing any of them with personal information.
11. Information Security
IMCO employs reasonable and current security methods to prevent unauthorized access, maintain data accuracy, and ensure correct use of information. User’s account information and profile are password-protected. IMCO recommends that users not divulge their passwords to anyone. IMCO will never ask users for their password in an unsolicited phone call or in an unsolicited e-mail. Users should sign out of their account and to close their browser window when they have finished their session. This is to help ensure that others cannot access the user’s personal information and correspondence if users share a computer with someone else or use a computer in a public place where others may have access to it.
Whenever users voluntarily disclose personal information online, for example on message boards, through e-mail or in chat areas, that information can be collected and used by others. No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while IMCO tries to protect user’s personal information, IMCO cannot ensure or guarantee the security of any information users transmit to IMCO, and users do so at their own risk.
12. Breach Notification
In the event IMCO determines the occurrence of a data security incident, IMCO will notify users by email, US mail, telephone, or other means as permitted by law.
12. User Ability to Access, Update and Correct Personal Information
In order to ensure that user personal information is correct and up-to-date, at any time users may visit their personal profile at imcousa.com/dashboard. Through their personal profile users may: (a) review and update their personal information that IMCO has already collected; (b) choose whether or not they wish IMCO to send them information about IMCO, or promotional material from some of our partners; or (c) choose whether or not they wish IMCO to share some of their personal information with third parties.
13. Data Collection From Children
IMCO does not knowingly collect any information from children.
14. Changes to Privacy Policy
IMCO reserves the right, at any time and without notice, to add to, change, update or modify this Privacy Policy, simply by posting such change, update or modification on the Website. Any such change, update or modification will be effective immediately upon posting on the Website
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