It is important that you read this Policy together with the Terms and other privacy notices or fair processing notices that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
By accessing or using the Website, you signify that you acknowledge, accept, and agree with all the terms of this Policy, so do not use or access this Website if you disagree with any part of this Policy. You should check this page from time to time to ensure that you continue to agree to the terms of this Policy.
Our Contact Information and DPO
5020 Ash Grove Drive
Springfield, Illinois 62711
1 (217) 529-6601
We have appointed a data protection officer (“Data Protection Officer” or “DPO”) who is responsible for overseeing questions about this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our DPO using the details set out below.
Data Protection Officer
Changes To This Policy
This Policy was last updated on May 18, 2018.
2) THE DATA WE COLLECT ABOUT YOU
BUNN collects information about you and your use of our websites through various means, including directly when you provide information to us and automatically from your access, use, or interaction with our websites. By accepting our Policy and Terms, you are confirming you have read and understand our policies including how and why we use your information.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username, or similar identifier.
- Contact Data includes a billing address, shipping address, email address, and telephone number.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, or feedback responses.
- Usage Data includes information about how you use our website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
3) HOW WE COLLECT DATA ABOUT YOU
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise; this includes personal data you provide when you:
- purchase our products;
- create an account on our Website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics provided by Google based outside the EU
4) HOW WE USE YOUR PERSONAL DATA
BUNN uses the information we receive about you for the purposes described in this Policy. We process much of the personal data received about you through our Website on the legal basis of BUNN’s legitimate interests in providing the Website and its functionality to you. Such processing is necessary for the purposes of the legitimate interests pursued by BUNN or by our service providers related to the Website. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing. Importantly, we will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- When you allow us to collect your personal data by expressly consenting to receive direct marketing communications via email or (You have the right to withdraw consent to marketing at any time by contacting us at DPO@bunn.com ).
- Where you allow us to process your personal data on the basis of that consent (You have the right to withdraw consent at any time by contacting us at DPO@bunn.com).
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purposes For Which We Will Use Your Personal Data
We have set out below, descriptions of ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. (‘Legitimate Interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at DPO@bunn.com). Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our DPO at DPO@bunn.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful Basis for Processing|
To register you as a new customer
a) Necessary for our legitimate interests (to provide you with our products or services)
To process and deliver your order including:
a) Manage payments, fees and charges
b) Collect and recover money owed to us
e) Marketing and Communications
a) Performance of a contract with you
b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
a) Notifying you about changes to our Terms or Policy
b) Asking you to leave a testimonial
c) To enable you complete a survey
d) Sending you marketing communications to notify you about our new initiatives or services
e) Marketing and Communications
a) Necessary to comply with a legal obligation
b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
c) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
e) Marketing and Communications
a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
a) Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
You can ask us to stop sending you marketing messages at any time by logging into the Website and unsubscribing , by selecting the unsubscribe link on any marketing message sent to you or by contacting us at DPO@bunn.com at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change Of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or legally necessary. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at DPO@bunn.com.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5) DISCLOSURES OF YOUR PERSONAL DATA
When you access or use our Website, we collect, use, share, and otherwise process your personal data as described in this Policy. BUNN will not share, sell, rent, or otherwise disclose your personal data to third parties without your consent or another valid legal basis permitted by law, including to:
- We share personal data with our service providers on the legal basis of BUNN’s legitimate interests in providing you with the Website. Our engagement of service providers is often necessary for us to provide the Website to you, particularly where such companies play important roles like helping us keep our Website operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Website, but help us make it better, like by helping us conduct research into how we could better to serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Website better.
- Internally within BUNN and with our subsidiaries and affiliates. BUNN’s personnel may have access to your information as needed to provide and operate the Website in the normal course of business. This includes information regarding your use and interaction with the Website.
- Professional advisers including lawyers, bankers, auditors, and insurers based that provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities based that require reporting of processing activities in certain circumstances. We may be required to disclose Website user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Website or using the BUNN name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6) DATA SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, and availability. We regularly test our website, data centers, systems, and other assets for security vulnerabilities. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7) DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at DPO@bunn.com.
8) YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data. This enables you to ask us to delete or remove personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
- Request restriction of processing your personal data of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. This enables you to ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What We May Need From You We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time Limit To Respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9) DATA TRANSFERS
BUNN is headquartered in the United States, and we have operations, entities, and service providers in the United States and throughout the world. Many of our external third parties are based outside the European Economic Area (“EEA”), so their processing of your personal data will involve a transfer of data outside the EEA.
We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact our DPO at DPO@bunn.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Do Not Track
BUNN does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use Website. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.
Your California Privacy Rights
Under California Civil Code Section 1798.83 (known as the “Shine the Light” law), BUNN members and customers who are residents of California may request certain information about our disclosure of personal data and information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at DPO@bunn.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
10) UPDATES TO POLICY
BUNN may modify this Policy from time to time. The most current version of this Policy will govern our use of your information and will be located at http://www.bunn.com/privacy-policy . You may contact us to obtain prior versions. We will notify you of material changes to this Policy by posting a notice at the Website or by emailing you, if applicable, and provide an overview of any changes.