Privacy Policy

Last updated: October 5, 2023

Objective and Scope

ITAD360, a company based in the United States, specializes in distributing and reselling IT products and services to corporations and legal entities worldwide. We provide comprehensive technology and supply chain services, supporting management, logistics, technology distribution, mobility device life-cycle, and training for our enterprise customers. For more details about ITAD360, please refer to the “About Us” section on our website.

ITAD360 offers enterprise customers access to a variety of product and service offerings, each of which may have its own specific privacy policy. These individual privacy policies may override or complement the terms outlined in this Privacy Statement. We strongly recommend that you carefully review the privacy policy associated with any specific offering before using it.

This Privacy Statement outlines how we collect, use, store, and share your Personal Data, both offline and online, along with your rights and options regarding your Personal Data. If you are an employee, contractor, or job applicant, please be aware that your Personal Data collected in those contexts will be subject to a separate privacy notice that we provide as needed. It’s important to note that this Privacy Statement does not apply to any Personal Data we access or receive when acting as a data processor on behalf of our enterprise customers.

While we encourage you to read the entire Privacy Statement, here are some key highlights:

• Each offering may have its own unique privacy policy; be sure to review it before using the offering.
• We collect both Personal Data and other information from various sources, including direct interactions with you, your devices, and third-party sources.
• We do not use or share your Personal Data in ways not described in this Privacy Statement.
• Providing accurate and up-to-date Personal Data is essential for us to conduct business with you and process transactions.
• You have the option to opt out of specific uses of your Personal Data, such as marketing emails or data deletion requests.
• We employ technical and organizational measures to secure your Personal Data, although we cannot guarantee complete protection against unauthorized access or criminal activities by hackers.

1. General Principles for Personal Data Processing

Personal Data collected by ITAD360 will be handled in accordance with established policies and relevant federal, state, local, and international laws, rules, and regulations. Our principles for processing Personal Data include:

1. Fair and lawful processing.
2. Collection of Personal Data for specific, explicit, and legitimate purposes.
3. Ensuring collected Personal Data is adequate, relevant, and not excessive for the intended purposes.
4. Accuracy and timely updates of Personal Data.
5. Protection against unauthorized access and processing using appropriate security measures.
6. Retaining identifiable Personal Data only for as long as necessary for the purposes it was collected.

If ITAD360 processes Personal Data for purposes other than those outlined in this Privacy Statement, we will provide notice of these changes, specify the purposes, and identify the recipients of the Personal Data.

2. Collection of Personal Data

ITAD360 may collect Personal Data from various sources, including but not limited to:

• Information provided by you voluntarily, such as when you communicate with us, register for an event, make purchases, or submit feedback.
• Information collected automatically when you visit our website or interact with our digital content or emails.
• Information received from other users of our website.
• Information obtained from resellers, distributors, vendors, and service providers.
•  Information from our customers and third-party customers who contract with us for services.
• Data obtained from data providers, publicly available sources, affiliates, subsidiaries, and third parties.

The types of Personal Data collected may include:

• Identity Data (e.g., name, username, title, company name, government-issued identification number).
• Contact Data (e.g., billing and shipping addresses, email, phone numbers).
• Financial Data (e.g., bank account details, payment card information, credit history).
• Transaction Data (e.g., payment details, product and service purchase history).
• Technical Data (e.g., IP address, device information, browser details).
• Profile Data (e.g., username, account number, interests, feedback).
• Usage Data (e.g., website and service usage, chat and form inputs).
• Preference Data (e.g., marketing and communication preferences).
• Professional Data (e.g., company affiliation, job title, office location).
• Sensitive Personal Data (e.g., government identification, account credentials, financial details) subject to additional protections and privacy rights.
• Other data collected with your consent or as required.

3. Cookies and Other Website Usage Information

Our website, digital content, and emails may use automated tracking technologies, including cookies and web beacons, to monitor and collect information about your interactions. Cookies are small text files stored on your device, helping us gather information such as browser type, page visits, and language preferences. They serve various purposes, including security, navigation, content display, and personalization.

Our cookies can be categorized into:

• Strictly necessary cookies: Required for website operation, e.g., secure login.
• Analytical/performance cookies: Used to analyze website usage and improve user experience.
• Functional/tracking cookies: Recognize repeat visitors and track referral sources.
• Targeting cookies: Record your website visits, page views, and clicked links for tailored advertising.

Cookies can be session-based (expire upon leaving the website) or persistent (stored for longer periods). We also employ “session replay technology” to log user interactions, keystrokes, and mouse movements on our website.

We may interact with third-party widgets on our website, allowing you to engage with those third parties. Clicking on such widgets may lead to those companies’ collecting information about your activities on our site.

To adjust your cookie preferences, refer to the “Your Privacy Rights” section below.

A “web beacon” (often referred to as a clear pixel or pixel tag) is an electronic image placed within the website interface. It helps us identify when you access specific parts of the website. Web beacons can also be linked with certain website pages and HTML-formatted emails. Their functions range from tracking user actions on the website and monitoring email interactions to evaluating the effectiveness of our marketing strategies and gathering data on website usage and email feedback.

Our website features interactive “widgets” from various third parties. These are typically marked by the third-party platform’s logo, either at the top or bottom of our website. Should you choose to click and engage with one of these widgets, the respective company will instantly gather data about your activity on our site.

4. Use of Personal Data

ITAD360 utilizes Personal Data for various purposes, including but not limited to:

• Registering you as a customer.
• Operating, maintaining, and enhancing the website and our offerings.
• Understanding user preferences to improve user experiences.
•  Researching and analyzing website and marketing effectiveness.
•  Managing accounts receivables.
•  Processing orders, deliveries, and payments.
•  Developing new offerings.
•  Complying with legal obligations.
•  Safeguarding website security and safety.
•  Communicating directly with you via newsletters, promotions, and customer support.
•  Delivering personalized advertising.
•  Monitoring and recording communications.
•  Verifying your identity.
•  Sharing data with credit reference, fraud prevention, and law enforcement agencies.
•  Compiling aggregated statistics.

We may combine and enhance collected Personal Data with information from third parties. Additionally, we may use your Personal Data to generate anonymized, aggregated data that cannot identify you.

Change of Purpose: We will use your Personal Data only for the purposes for which we collected it, unless there is a compatible new purpose. If we intend to use your data for an unrelated purpose, we will notify you and explain the legal basis.

Credit Reference Checks, Fraud Prevention, and Denied Parties: We may share your Personal Data with credit reference, fraud prevention, and denied party agencies to prevent fraud, money laundering, and verify identity. These agencies use the data for these purposes and may retain it.

Please note that we may process your Personal Data without your knowledge or consent when required or permitted by law.

5. Sharing of Information

We share your Personal Data either with your consent or when necessary to fulfill a transaction or provide a requested Offering. Additionally, we may share Personal Data when required by law or to respond to legal proceedings, safeguard our customers, protect lives, maintain Offering security, or protect ITAD360’s rights and property.

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6. Options Concerning Your Personal Information

Cookies Management: You have the freedom to either accept or decline cookies. Many of our sites present cookie banners where you can indicate your cookie preferences. Though most browsers default to accepting cookies, you have the ability to change this. Options include: (i) setting your browser to notify you upon receiving a cookie, allowing you to decide whether to accept; (ii) disabling current cookies; and (iii) instructing your browser to refuse cookies automatically. Be aware, however, that without cookies some website features might malfunction or not recognize your user profile, resulting in less personalized services.

Tailored Advertising: During your visit, both we and some third-party cookie services may employ cookies and related technologies to record your browsing habits over time and across various sites, aiming to show ads aligned with your interests. You can prevent this tracking by deactivating advertising cookies. Remember, these settings are specific to each device and browser, so adjustments are required for each combination.

Marketing Messages: At any point, you can decline marketing communications from us. Just click on the “unsubscribe” or “opt-out” link in our emails. If you wish to exclude yourself from other marketing channels (like postal or phone marketing), reach out to us via the provided contact details or through our preference center.

Do Not Track Preference: Some browsers or devices offer a “Do Not Track” feature, signaling your preference against online tracking. Currently, our site doesn’t respond to these signals, meaning we neither alter your website experience nor the data we collect based on this preference.

Preference Hub: Several of our affiliated entities maintain a preference hub where you can set your communication choices, allowing you to easily choose or deselect your messaging preferences using the provided web form.

7. Additional Privacy Details

Security of Personal Data: ITAD360 employs technical and organizational measures to safeguard your Personal Data from unauthorized loss, misuse, or disclosure. These measures include robust user access controls, a segmented network architecture, and comprehensive employee policies and training. However, please be aware that no data transmitted over the Internet can be guaranteed 100% secure. While ITAD360 endeavors to protect all Personal Data, we cannot guarantee absolute security against hacking or other malicious activities. In the event of a security breach involving your personally identifiable information, as defined by applicable laws, stored by or for us, we will notify you in accordance with relevant laws.

Compliance: ITAD360 utilizes a self-assessment approach to verify adherence to this Privacy Statement. We periodically validate that the Privacy Statement is accurate, comprehensive for the intended information coverage, prominently displayed, implemented, and accessible. If you suspect that your Personal Data has been processed or disclosed in violation of this Privacy Statement, we encourage you to voice your concerns using the contact information provided in the “Questions and Contact Information” section below. ITAD360 will investigate and seek resolution for any complaints and disputes regarding Personal Data use and disclosure.

Accuracy: Ensuring the accuracy of your Personal Data is your responsibility. ITAD360 will only utilize Personal Data in a manner consistent with the purposes for which it was initially collected or subsequently authorized by you. To ensure data accuracy, ITAD360 will take reasonable steps to maintain Personal Data that is current, complete, accurate, and relevant to its intended use.

Privacy Rights for European Economic Area (EEA), United Kingdom (UK), and Switzerland Residents

For individuals from the European Economic Area, Switzerland, or the United Kingdom, this section outlines data protection rights, the primary authority for your Personal Data, and the grounds for processing your Personal Data.

As an individual in the EEA, Switzerland, or UK, you have rights concerning your Personal Data:

• Access & Portability: You’re entitled to access your Personal Data in our possession and receive a transferable copy.
• Data Rectification: You can request updates or corrections to your Personal Data.
• Data Erasure: Subject to specific exceptions and limitations, you can ask for the removal of your Personal Data.
• Objection to Processing: When we process data based on legitimate interests, you can object.
• Processing Restrictions: You can request limited processing or halt further use of your Personal Data. Even if processing is limited, we can retain your Personal Data.
• Consent Management: If your Personal Data was collected with consent, you can retract it anytime. This doesn’t impact prior legal data processing or processing not based on consent.
• Lodge Complaints: You can file complaints with a data protection authority regarding our data handling. Unsatisfied with our response? Reach out to your local data protection authority. [Link to authorities for EEA and UK]

Controller Identity: In European data protection context, the primary controller of your data is the ITAD360 Affiliate based in the EEA, UK, or Switzerland that gathers the Personal Data. For inquiries about submitted data, contact the respective Affiliate.

Grounds for Data Processing (for EEA, Switzerland, and UK Residents): The basis for data collection hinges on the nature of the Personal Data and its collection context. Typically, we collect data: (i) required for our contractual obligations, (ii) grounded in our legitimate interests not superseded by your rights, or (iii) with your explicit consent. Sometimes, legal mandates or vital interests necessitate data collection.

If we demand data under a legal or contractual obligation, we’ll specify the mandate and potential repercussions of non-submission.

Our legitimate interests typically encompass platform operations, service communications, and activities like addressing your questions, refining our platform, marketing, or combating illegal activities. Should there be other valid reasons, they’ll be communicated explicitly.

Upon collecting data with consent, any consequences of refusal or retraction will be clarified.

8. Your Choices Regarding Personal Data

Cookies: You have the option to accept or decline cookies. Many of our websites include cookie banners that enable you to proactively select your preferred cookie types. Furthermore, most web browsers automatically accept cookies, but you can typically adjust your browser settings to reject them if you wish. Disabling or rejecting cookies may affect the proper functioning of certain features and services on our websites, as we may be unable to recognize and associate you with your account(s). Additionally, the Offerings provided during your visits may be less relevant and tailored to your interests.

9. Your Privacy Rights

We will respond to requests from individuals seeking to exercise their privacy rights in accordance with applicable privacy laws. We may deny specific requests or partially fulfill them based on our legal rights and obligations. As previously mentioned, if you are an employee, contractor, or job applicant, your rights concerning Personal Data collected in those contexts will be detailed in a separate privacy notice provided to you when appropriate.

We will not discriminate against individuals exercising their privacy rights. We will not withhold products or services or apply different pricing based on the exercise of your privacy rights.

Eligible individuals can submit requests to exercise the privacy rights described below through any of the following methods:

• Send an email to [email protected]

We will take reasonable steps to verify your identity before responding to your requests. The verification process will vary depending on the sensitivity of the Personal Data and whether you have an account with us.

You may appoint an authorized agent to make requests on your behalf. When submitting the request, please ensure the authorized agent identifies themselves as such.

10. Data Retention

We retain each category of Personal Data, including Sensitive Personal Data, as long as we have an ongoing legitimate business need to do so. Factors influencing the need for retention include regulatory requirements we are subject to, the possibility of legal claims against us, the necessity of Personal Data for providing services, and the types and sensitivity of Personal Data being processed.

When we no longer have a legitimate business need to process your Personal Data, we will either delete or anonymize it. If this is not possible, such as when your Personal Data is stored in backup archives, we will securely store and isolate your Personal Data from further processing until deletion becomes possible.

For European Union or UK residents, all Personal Data related to you and received and stored by ITAD360 is erased after 5 years, except for any Personal Data in documents and files that must be retained longer under applicable laws, such as personal data on VAT invoices.

11. Not for Children

Our websites are intended for use solely by individuals aged 18 and older and are not directed at children under 18. ITAD360 does not knowingly request or collect Personal Data from individuals under 18.

12. Third-party Websites

In addition to offering access to Offerings, our website may contain links to other websites and web services. This Privacy Statement does not apply to those websites and services, and their privacy practices may differ from those outlined in this Privacy Statement. If you provide Personal Data to any of these other websites or services, your Personal Data will be governed by their respective privacy policies. We recommend carefully reviewing the privacy policy of any website or web service you visit.

13. Revisions and Updates to this Privacy Statement

ITAD360 may, at its sole discretion, periodically revise this Privacy Statement to reflect changes in our business practices or new disclosure requirements under applicable privacy laws. In case of revisions, we will notify you by posting the updated Privacy Statement on this website and/or sending you an email notification, as required by applicable privacy laws. Changes will be effective from the date ITAD360 posts the revised Privacy Statement on the website. If applicable data protection laws mandate your consent for changes in the use of your Personal Data described in our updated Privacy Statement, we will seek that consent.

14. Questions and Contact Information

For inquiries or concerns regarding this Privacy Statement, ITAD360’s privacy practices, the collection or use of your Personal Data, or the exercise of privacy rights, please contact us at [email protected]. Our Data Protection Officer can be reached at [email protected].