This Privacy Notice describes the types of personal information Requis (“Requis,” “us,” “we” or “our”) collects through <https://requis.com>, <http://supplychain.requis.com> and all mobile applications that provide access to the Requis Marketplace (the “Site”), and how we collect, use, and share that information. This Privacy Notice does not govern our collection of personal information through any other website or other means, other than through the Site.
Our processing of personal data, such as your name, address, e-mail address, or telephone number, shall be undertaken consistent with the requirements of applicable privacy laws, including to the extent applicable, but not limited to, the General Data Protection Regulation (“GDPR”). The purpose of this Privacy Notice is to provide to users and potential users of our website information about the nature, scope, and purpose of the personal data we collect, use and process and to advise data subjects of their rights. Whether we serve as the data controller or processor, Requis has implemented numerous technical and organizational measures to ensure the protection of personal data processed through the Site. However, Internet-based data transmissions may in principle have security gaps, so please understand that absolute protection is not assured.
II. PERSONAL INFORMATION WE COLLECT
A. Information You Give Us
You will be required to provide personal information to use the services offered through the Site. Once you provide us with your personal information, you are no longer anonymous to us. This information may include:
Registration Information: When you sign up for the Site, you are required to provide information such as your name, username, password, email address, and other information used to populate your profile.
Additional Information: Additional information that you provide to us, including through your interactions with the Site (including interactions regarding assets listed on the Site), feedback, pictures you upload, messages, emails, posts to public discussion boards, event registrations, answers to surveys or questionnaires that you may submit.
B. Location Information
Certain areas or features of the Site require the collection and use of your physical location information. For example, if you use the Site on a location-enabled device (including GPS, cellular, and Wi-Fi networks) or from your browser. Your access to and use of these areas will be on the basis of your consent.
C. Automated Information Collection
We collect and use certain information about your use of the Site through the use of tracking technologies or by other passive means. This “passively collected” information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other webpages you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:
Log Information. When you access the Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, your computer operating system, mobile device and mobile operating system, name of your internet service provider, or your mobile carrier, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser. Our servers also automatically record what you click on while visiting the Site. Our collection and use of this information are on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.
Links. The Site may include links in a format that enables us to keep track of the IP addresses from which these links have been followed and the links you click on to leave the site. We also receive the URL of the site from which you came Our collection and use of this information is on the basis of our legitimate interest in improving the quality of our Site, product(s), and Requis business operations.
Aggregate Information. We may compile certain personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of people who have visited the Site and other user demographics. Such aggregate information does not identify you individually.
III. HOW WE USE PERSONAL INFORMATION
Requis complies with its obligations under applicable privacy laws by: keeping personal data up to date where needed based on the purposes for which the personal data is being processed; by not collecting or retaining excessive amounts of data; by ensuring that appropriate technical measures are in place that is designed to protect personal data from loss, alteration, misuse, unauthorized access, and disclosure as it is transmitted, stored, or otherwise processed, and by using appropriate measures to securely destroy personal data when it is no longer needed by Requis.
Personal information collected through the Site may be used by us and our affiliates for purposes of:
Responding to your questions and feedback;
Providing the services you select through the Site;
Contacting you, whether by email, postal mail, or telephone with information about the Site, our products, or our services;
For such purposes, as you may authorize at the time you submit the information;
Auditing, research, and analysis to maintain, protect, and improve the Site and our services;
Ensuring the technical functions of our network;
Improving and customizing the content and layout of the Site;
Developing new products and services;
Compiling personal information and other information collected through the Site on an aggregate basis; or
Serving advertisements to you.
IV. PERSONAL INFORMATION WE SHARE
We do not sell, rent, trade, or otherwise share personal information collected through the Site, except as described below:
In Connection with our Offerings. We share certain personal information collected through the Site with (i) other users of the Site, and (ii) as you otherwise provide your consent. The information which you upload, post, e-mail, submit or otherwise transmit in connection with the Site, such as content related to asset postings, bids placed, and content uploaded to other public areas of the Site, will be made public to users of the Site, including certain metadata related to such activities (such as timestamps). You are solely responsible for any such information you choose to post on or through the Site. All information that is posted to a message board, chat area, or other public areas of the Site may be shared by us with (i) other users of the Site, and (ii) as you otherwise provide your consent. Please be aware that anything you share publicly may be further shared by other users of the Site (for example, by emailing a screenshot of your post to non-users). We are not responsible for any such sharing of information you have shared publicly on the Site.
Subsidiaries and Affiliates. We may share personal information with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.
Service Providers. We work with third parties that provide services on our behalf. Such services may include website hosting, marketing, and website usage analytics. We may share personal information and non-personal information with these third parties for the purpose of enabling them to provide these services.
Consent. We may share personal information in accordance with any consent you provide.
Required by Law. We may disclose personal information or any information collected through the Site if we are required to do so by law or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.
Certain Transactions. We may disclose or transfer personal information or any information collected through the Site to third parties who acquire all or a portion of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
V. AGGREGATE INFORMATION
We may compile de-identified personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Site and demographic information about users of the Site. Such aggregate information does not identify you individually. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Notice, and for any other lawful purpose.
VI. YOUR CHOICES
A. Information You Provide
You can always choose whether or not to provide information on the Site. However, if you choose not to disclose certain information, you may not be able to register as a user of the Site, which may limit your access to certain portions of the Site.
B. Privacy Settings
By default, certain types of information you choose to submit will be made public to users of the Site. This includes your account username, content related to asset postings, bids placed, and content uploaded to other public areas of the Site. You can control whether other profile and activity information as described in Section II will be shared publicly with all users of the Site or limited to users that you have identified to us.
C. Communications From Us
If at any time you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at firstname.lastname@example.org.
D. Do Not Track
As described more in our Cookie Notice, you can configure your browser not to accept cookies or to notify you when a cookie is being sent.
E. Your Rights and Your Personal Data
Unless subject to an exemption under the GDPR, if your personal data is subject to the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of your personal data which Requis holds about you;
The right to request that Requis correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data be erased where it is no longer necessary for Requis to retain such data;
The right to withdraw your consent to the processing at any time of personal data to which you provided consent for processing;
The right to request that Requis provide you with a copy of your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction be placed on further processing;
The right to object to the processing of personal data (where applicable); and
The right to lodge a complaint with a data supervisory authority.
F. Transfer of Data Abroad
If your personal data is subject to the GDPR, Requis will transfer personal data from the European Economic Area (EEA) to a location outside the EEA only when there has been a documented adequacy determination, or where Requis has confirmed adequate privacy protections. If Requis transfers personal data to a third party acting as an agent of Requis, we will also obligate the third party to have adequate privacy protections in place.
Requis may transfer personal data to and on behalf of clients and third parties with whom Requis has an existing service agreement or as part of our legal obligations, each of which shall be subject to Requis policies, and only to the extent necessary for purposes of legitimate interests pursued by the data controller (or by a third party).
G. Automated Decision Making
Under the GDPR, data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent. We do not engage in automated decision-making directed toward you in this manner.
H. Further Processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
VII. INFORMATION STORAGE AND SECURITY
We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Site. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.
VIII. A SPECIAL NOTE ABOUT CHILDREN AND CALIFORNIA RESIDENTS
Children are not eligible to use the Site, and we ask that minors (children under the age of 16) not submit any personal information to us. If you are a minor, you can use the Site only in conjunction with your parents or guardians.
If you are a California resident, you have the right, pursuant to Section 1798.83 of the California Civil Code, to receive once a year, free of charge: (1) information identifying each third party company to whom we may have disclosed, within the past year, personal information pertaining to you for that company's direct marketing purposes; and (2) a description of the categories of personal information disclosed to that third party company in the immediately preceding calendar year. If you are a California resident and would like to make this request, please call 1.888.207.4588. In addition, please refer to the Section of this Privacy Notice entitled "Information Collection & Use."
IX. EXTERNAL LINKS
The Site may contain links to various websites that we do not control. When you click on one of these links, you will no longer be transacting business through the Site. Third-party websites maintain their own privacy policies, and we do not exercise any control over any of the third-party websites that may be linked to the Site. If you visit a website that is linked to the Site, you should consult that website’s Privacy Notice before providing any personal information. Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of personal information about you.
X. SPECIAL ADMONITIONS FOR INTERNATIONAL USE
The Site is hosted in the United States. All matters relating to the Site are governed exclusively by the laws of the State of Texas in the United States of America and not the jurisdiction in which you are located. If you are located outside of the United States of America and you contact us, please be advised that any information you provide to us will be transferred to the United States of America and that by submitting information, you explicitly authorize such transfer.
XI. UPDATES TO THIS PRIVACY NOTICE
We may change or update the Site or any of our policies and procedures without prior notice, except that if any changes are likely to have an adverse impact on your rights under data protection law, we will use reasonable efforts to notify you of the changes in advance in writing or by postal mail, and, where required, obtain your consent to our activities. We will post a notice on the Site to advise you of any significant changes to this Privacy Notice and indicate via the “Last Updated” legend in this Privacy Notice when it was most recently updated. Except to the extent that your express consent to any change or update is required under data protection law, your continued use of the Site signifies your continued assent to the terms of this Privacy Notice, as updated or amended at that time.
XII. QUESTIONS REGARDING THIS PRIVACY NOTICE
If you have any questions or comments regarding this Privacy Notice, please send us an email at email@example.com.
In certain circumstances, the data controller for the purposes of GDPR or other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Requis Inc. 21 Waterway Avenue, Suite 300 The Woodlands, Texas 77380 USA firstname.lastname@example.org
Any data subject may, at any time, contact us directly with any questions and suggestions concerning data protection. We encourage interested persons to raise any concerns about the collection, use, or processing of personal data using the contact information provided above. In the event of a privacy-related issue or complaint, we will investigate and attempt to promptly resolve any complaints and disputes regarding the use and disclosure of personal data.
For complaints that cannot be resolved, if your personal data is subject to the GDPR, we commit to cooperating with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, and comply with the advice given by the panel or Commissioner about personal data transferred from the EU or Switzerland.