PRIVACY POLICY
This Transparency-One Privacy Policy (this “Privacy Policy”) is designed to inform you of the policies and procedures that will apply to the collection, security, use, and disclosure of information by Transparency-One, Inc., a Delaware corporation, and its subsidiaries (“Transparency-One,” “we,” “us,” or “our”) in connection with our operation of the Transparency-One website and platform.
Section 1
About Transparency-One
Transparency-One, Inc. owns and operates an online supply chain mapping and management platform called Transparency-One. Through Transparency-One, we collect information from Transparency-One-subscribing Buyers (“Buyers”), Transparency-One-subscribing suppliers (“Suppliers”), and data providers and other public and private third-party sources (such as governmental databases) (“Data Providers”), in order for that information to be shared with certain other Suppliers and Buyers for use in their supply chain mapping and management processes and in other services that we may offer from time to time (collectively, our “Services”).
Section 2
How Transparency-One Collects, Uses, and Shares Information
This section describes in more detail how we collect, use, and share different types of information
A. Transparency-One Content.
Our Services allow Suppliers, Data Providers and Buyers to provide, upload or enter content into Transparency-One (“Transparency-One Content”) to be stored and shared with other Transparency-One users. Transparency-One Suppliers may use platform functionality to indicate certain types of information that may be disclosed or not disclosed to other Transparency-One subscribers. In general, and except as required by law, we will process Transparency-One Content only as required in order for us to provide our Services to Buyers and Suppliers (please see our standard Supplier Agreements for additional information regarding our Services provided to Suppliers) or otherwise in accordance with consent or the reasonable written instructions of the applicable Supplier, Data Provider, or Buyer. We may disclose the fact that such Suppliers subscribe to the Transparency-One platform to Transparency-One subscribers and potential subscribers.
As part of our Services, we assemble and retain data from Transparency-One Content for the purposes of benchmarking and providing comparative and other generalized analyses and reports (“Benchmarking”). Any data we report from Benchmarking is aggregated and anonymized.
It is important to us that Transparency-One Content remains accurate, complete, and up-to-date. As we rely on Buyers, Suppliers and Data Providers for Transparency-One Content, we take steps to ensure these parties understand the importance of keeping the information they maintain and share through Transparency-One as accurate and current as possible. However, each Buyer, Supplier, and Data Provider is ultimately responsible for the accuracy and completeness of the Transparency-One Content it provides to us.
B. Cookies.
We collect certain information automatically from visitors to our website, such as Internet Protocol (IP) addresses, access times, browser types, device types, domain names, durations of visit, and referring URLs (if applicable), through the use of cookies and similar methods. A cookie is a small piece of text sent to a browser by a website accessed through the browser. Cookies help websites remember information about visitors. We use information from cookies and similar methods and share it with other organizations with which we have a commercial relationship (e.g., Google Analytics) to measure the use of our website, to improve the functionality and content of our website and our Services, and to facilitate usage by visitors.
Visitors to our public website can reset their browsers either to notify them when they receive cookies or to refuse to accept cookies. However, by refusing to accept cookies from the Transparency-One platform, a subscriber will not be able to use the features available on the Transparency-One platform or through our Services.
C. Personal Information.
This subsection details how we collect, use, and disclose Personal Information (as defined below). For purposes of this subsection, (i) “Personal Information” means individually-identifiable information that, alone or when in combination with other information, may be used to identify, contact, or locate a specific person, such as a name, address, phone number, username, or email address; and (ii) “you” or “your” refers to the individual who is the subject of the relevant Personal Information, regardless of whether that individual is an Transparency-One subscriber.
(i) Content Personal Information.
We do not control the type or accuracy of the Transparency-One Content that Suppliers, Data Providers, and Buyers provide to us, which may include Personal Information (“Content Personal Information”). Most of the Transparency-One Content, including Content Personal Information, consists of information that Suppliers and Data Providers provide to us in response to requests from Buyers. Each Supplier, Data Provider, and Buyer is responsible for managing the Content Personal Information it enters into Transparency-One and for taking all measures necessary to comply with applicable privacy laws to ensure we may lawfully process, use, and disclose such Content Personal Information to provide our Services.
To the extent applicable privacy laws require your consent to be obtained prior to or during the course of our processing any Content Personal Information about you, the Supplier, Data Provider, or Buyer who provided or entered your Content Personal Information into Transparency-One is responsible for obtaining your consent to us processing your Content Personal Information for purposes of providing our Services.
If any Content Personal Information about you has been provided without your consent or is incorrect, you should first ask your employer to take the necessary steps to have it removed from or corrected in Transparency-One.
(ii) Information about Transparency-One Users.
Each Buyer, Supplier, and Data Provider will have at least one, and sometimes many, individuals registered as users of its Transparency-One account. We collect information, including Personal Information, when individuals register as users of a Transparency-One account and thereafter when they access our Services (“User Personal Information”). For example, if you are requesting to be set up as a user of a Buyer’s account, we will ask you to provide your name, email address, the name of your employer, and other information we may need in order to activate and maintain your user account.
We may use your User Personal Information to contact you from time to time in connection with our Services, such as to address any issues or complaints related to your use of Transparency-One, provide you with information about Transparency-One or our Services, verify your identity or credentials, provide any required legal notices to you, or notify you if we believe your use of our Services violates any of our terms or policies.
(iii) Communications with Transparency-One.
We collect information when we receive communications from Transparency-One users and third parties. The information we collect from communications includes Personal Information received via emails, telephone calls, postal mails, online chats, and inquiries through our website (“Communicated Personal Information”).
We may use your Communicated Personal Information to respond to you, provide you with information about Transparency-One or our Services, provide any required legal notices to you, or address any issues related to your communications.
(iv) International Privacy Issues.
Your Personal Information may be transferred outside of the country where you reside or are located, including to countries whose laws do not provide the same level of protection for your Personal Information as the laws of your home country. However, we are committed to protecting the privacy and confidentiality of Personal Information when it is transferred and we will take reasonable steps to ensure that, in the event we transfer your Personal Information to a location outside of your home country, your Personal Information is protected and our practices and procedures comply with all relevant privacy laws.
(v) Obtaining Access to Your Personal Information.
Upon your written request, and subject to certain exceptions, we will inform you of the existence, use, and disclosure of your Personal Information and will give you access to that information.
You have the right to request access to and correction of any of your Personal Information that we hold. You should first ask your employer (or its customer, if applicable) to obtain such access or to take the necessary steps to have your Personal Information removed from or corrected in Transparency-One; however, you may contact us at any time as provided in Section 5 below to request assistance in accessing your Personal Information. If access to your Personal Information is denied, we will notify you in writing, give reasons for the denial, and inform you of the recourses open to you. If access is granted, we will give you a reasonable opportunity to review your Personal Information. Your Personal Information will be provided to you in an understandable form within a reasonable time, generally within 30 days. Transparency-One may extend such 30-day period by up to an additional 30 days if meeting the time limit would unreasonably interfere with the activities of Transparency-One or the time required to undertake any consultations necessary to respond to your request would make the time limit impracticable to meet. You will be able to challenge the accuracy and completeness of your Personal Information and have it amended as appropriate.
(vi) Retention.
In general, Transparency-One retains information in order to meet business, tax, legal, regulatory and archival requirements. We retain the personal information we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our Services and other contractual and legal obligations.
Section 3
Disclosures to Affiliates and Service Providers.
We disclose information we collect to our related corporate affiliates and service providers who assist us in providing the Services and are bound by relevant confidentiality and data protection requirements.
Section 4
Safeguarding Measures and Transfer of Information Overseas.
We are committed to protecting the security of the information we collect. We use a variety of security technologies and procedures to help protect such information from unauthorized access, modification or disclosure and from misuse, interference and loss. We collect and store information electronically. The Transparency-One platform is hosted for persistent storage in secure servers that are protected in controlled facilities located in the EU. We regularly monitor and update our security procedures to ensure we have industry-standard or better measures in place at all times to protect against unintended disclosures or use of the information we collect.
Section 5
Contact Information
We welcome any questions or comments you might have about our Services and the information provided in this Privacy Policy. We recommend employees of Suppliers and Buyers raise their questions, requests or complaints with the Supplier or Buyer for whom they work at first instance. Questions, requests, or complaints received directly by Transparency-One in the first instance may be referred to the relevant Transparency-One Supplier or Buyer (or both).
If you have any questions about this Privacy Policy or our Services, any problems or complaints about how we have collected, used, stored, handled and/or disclosed information, or wish to make a request to access, erase, or correct any information, please contact us by telephone or email as follows:
Telephone: 1-800-241-3317
Email: info@Transparency-One.com
Section 6
Changes to this Privacy Policy.
We reserve the right to amend this Privacy Policy from time to time, such as to account for new laws and technologies, changes to our Services, and for other reasonable purposes. In the event we amend this Privacy Policy, we will post a notice on our website (www.Transparency-One.com).
