ELECTROSMART PRIVACY POLICY

PLEASE NOTE:
This Site is not directed at children. Visitors and Authorized Customers are required to be eighteen years or older.

1. Our Commitment to Privacy

Your privacy is important to us. so we are providing this notice to describe and explain our online information practices and the choices you can make about the way you share information with us and how information is collected and used.

This statement governs our privacy policies of both users of the Sites ("Visitors") and those who register, subscribe or transaction with us in regard to the various products and services offered by this Site (collectively, "Services") ("Authorized Customers").

This policy applies where we are acting as a data controller with respect to the personal data your provide, where we determine the purposes and means of the processing of that personal data.

2. "Personally Identifiable Information"

In general, you can visit this website without telling us who you are or revealing any personal information about yourself. There are times, however, when we may need information from you.

Personally Identifiable Information [Personal Data] refers to any information that identifies or can be used to identify, contact, or locate the individual to whom the information pertains, including, but not limited to, name, address, phone number, fax number, email address, financial profiles, social security number, and credit card information. Personally Identifiable Information does not include information that is collected anonymously (without identification of the individual user) or demographic information not connected to an identified individual.

What personal data is collected?
We may collect basic user profile information from all of our Visitors. Personal information like your name, postal address and e-mail address is obtained only when you voluntarily submit it. We collect the following additional information from our Authorized Customers: the names, addresses, phone numbers and email addresses, the nature and size of the business, and information needed to personalize the the product or service that the Authorized Customer intends to purchase.

What organizations are collecting the information?
In addition to our direct collection of information, our third party service vendors (such as credit card companies, clearinghouses and banks, affiliate vendors) may collect this information from you during their transaction service process. We use both Paypal and Stripe as our payment gateways.

We do not control how these third parties use such information, soif you have any concerns, please check their terms of service on their own websites. Some of our third parties are intermediaries that act solely as links in the distribution chain, and do not store, retain, or use the information given to them.

In general we collect infromation through visits, registration, surveys and other online forms as part of:

• Registration to receive newsletters, access free samples, whitepapers, or access to protected content on the site
• An ongoing sales process
• While providing technical support, consultation, live chat, or product information
• Through the process of maintaining and upgrading our products
• Through automated means such as communications protocols, e-mail communications and cookies

Types of personal data we collect.

There are various types of personal data we collect and process: Account data and Usage Data.

Account data includes data you opted to include when signing up for access, subscription or membership to any product or service we provide. This includes your name and email address, and any other data relevant for the specific purpose. The processing of this data is required for the proper administration of our website and business, and in performing any contract between you and us, such as ensuring you have access to site content and specific purchased content.

Profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. Profile data may be processed to enable and monitor your use of our website and services for the purpose[s] for which you provided it.

Program Data includes any personal data you provide as part of engagement with any of our paid products and services. This might include your answers to questions, quizzes, polls, group discussions or other program submissions.

Usage data is data collected about your use of our website and services]. This may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of our website or service. We access this usage data via our analytics tracking systems, including Google Analytics. No personally identifiable information is used.

Service data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

Publication data includes information you post for publication on our website or through our free services.

Communication & Support data - is contained in any communication you submit to us for any purpose. This information may be processed for the purpose to responding to your communication, resolving any requests for service or support, or for the purpose of offering, marketing, selling and supporting relevant goods and/or services to you.

This may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. Correspondence data may be processed for the purposes of communicating with you and record-keeping; ensuring the proper administration of our website and business and communications with uses.

Transaction data – we process data relevant to completing a transaction to provide you with paid products and services. We do not have access to any data that forms the payment part of the transaction. This is performed by secure third parties to ensure maximum protection of your payment data. The transaction data we process includes only that for the purpose of supplying the requested product or service. This may include your contact details, transaction details and delivery details.

Subscription Data – we process data you provide when subscribing to our notifications and newsletters.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

We do not collect the following types of sensitive data:

• Race or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union memberships
• Genetic or biometric data
• Health or mortality
• Sex life or sexual orientation

However, if you submit such information as part of a post or comment in any format on our Site, it will be retained in full context of data your provided, and only for the purpose that you provided it. You have full control as to whether you use your real personal identity information or an avatar name to sign your submissions.

3. Usage of Personal Data

How does the Site use personal data?
We use Personally Identifiable Information to customize the Site, to make appropriate service offerings, and to fulfill buying and selling requests on the Site. We may email Visitors and Authorized Customers about opportunities or information related to the subject matter of the Site. We may also use Personally Identifiable Information to contact Visitors and Authorized Customers in response to specific inquiries, or to provide requested information.

Providing your personal data to others

We may disclose your personal data to any member of our group of companies (including our holding company and its subsidiaries) as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We may disclose your personal data to our insurers and/or professional advisers only insofar as reasonably necessary for the purposes of [obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose specific data to our suppliers and subcontractors only as reasonably necessary for delivering our products and services to you.

We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

Where you have elected for us to do so, we may disclose your data to selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. In each instance, the third party will act as a data controller in relation to the data that we supply to it; and upon contacting you, each third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

Information shared with third party advertising companies
We use Google Adsense to serve ads when you visit our Sites. These companies may use cookies, which are designed to improve your online experience. Google may use information (but NOT your name, address, email address, or telephone number) about your visits to our Sites to allow them to serve advertisements about goods and services that will be more relevant to you. Google Adsense uses the DoubleClick DART cookie. You can opt out of using this cookie, click here.

Who else do you share my personal data with?
Personal data about Authorized Customers may be shared with other Authorized Customers who wish to evaluate potential transactions with other Authorized Customers. We may share aggregated information about our Visitors, including the demographics of our Visitors and Authorized Customers, with our affiliated agencies and third party vendors. We also offer the opportunity to "opt out" of receiving information or being contacted by us or by any agency acting on our behalf.

What partners or service providers have access to personal data from Visitors and/or Authorized Customers on the Site?
Electrosmart has entered into and will continue to enter into partnerships and other affiliations with a number of vendors. Such vendors may have access to certain Personally Identifiable Information on a need to know basis for evaluating Authorized Customers for service eligibility. Our privacy policy does not cover their collection or use of this information. Disclosure of Personally Identifiable Information to comply with law. We will disclose Personally Identifiable Information in order to comply with a court order or subpoena or a request from a law enforcement agency to release information. We will also disclose Personally Identifiable Information when reasonably necessary to protect the safety of our Visitors and Authorized Customers.

4. Storage & Transfer of Data

How is personal data stored?
Personal data collected by Electrosmart is securely stored and is not accessible to third parties or employees of Electrosmart except for use as indicated above.

How is other information used?
We may use other technologies to capture specific data, such as the pages you view, the items you download, the links you click, your access times, and your Internet Protocol (IP) address, domain name, and system configurations and settings, to help us understand how you use our site, serve you relevant content, and to assist you with questions you may have regarding our products and services.

International transfers of your personal data

Our group companies have offices in Australia and New Zealand. Our websites are hosted in, and data collected by our websites and online services is held and processed in the United States of America. Data for analytical purposes may also be processed in either Australia or New Zealand, or at the location of any third-party analytical service we engage.

Transfers between these countries will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from [source].

You acknowledge that personal data that you submit for publication through our website or services may be available, via the Internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Links

This web site contains links to other web sites. Please note that when you click on one of these links, you are moving to another web site. We have not reviewed these third-party sites and do not control them. We encourage you to read the privacy statements of these linked sites as their privacy policies may differ from ours.

Links to third-party websites from this website are provided solely as a convenience to you. Electrosmart does not assume responsibility for any of these sites, their content, or their privacy policies.

This Site does not endorse or make any representations about them or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites linked to this site, you do so at your own risk.

Commercial Links

Some links are to commercial products, which we at Electrosmart may gain an affiliate commission. In addition, some pages may display advertisements from Google or Amazon.com. We may, or may not gain
advertising revenue, or product revenue from users clicking on these links. Electrosmart has no liability and makes no warranty as to the suitability or quality of these products, unless expressely stated by us.

6. Cookies

What are cookies?

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Are cookies used on the site?
Cookies are used on this Site for a number of reasons - to obtain information about your preferences and the services you select. We also use Cookies for security purposes to protect you; for example, if an Authorized Customer is logged on and the site is unused for more than 10 minutes, we will automatically log the Authorized Customer off.

Cookies that we use

We may use cookies for the following purposes:

• authentication - to identify you when you visit our website and as you navigate our website.
• status - to help us to determine if you are logged into our website.
• personalization - to store information about your preferences and to personalize the website for you
• security - as part of security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
• advertising - we use cookies to help us to display advertisements that will be relevant to you
• analysis - to help us to analyze the use and performance of our website and services; and
• consent - to store your preferences in relation to the use of cookies more generally

Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies.] OR [We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website).] You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

https://support.google.com/chrome/answer/95647?hl=en (Chrome);

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

http://www.opera.com/help/tutorials/security/cookies/ (Opera);

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

https://support.apple.com/kb/PH21411 (Safari); and

https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

How does Electrosmart use login information?
Electrosmart uses login information, including, but not limited to, IP addresses, ISPs, and browser types, to analyze trends, administer the Site, track a user's movement and use, and gather broad demographic information. Occasionally, we may create a unique web URL link for certain visitors. If you visit one of these sites, you may find forms that are already filled out with your name, or other types of information you have previously indicated an interest in, based on information you have given us before. We may also personalize the content of newsletters, e-mail offers, invitations.

7. Maintenance of Personal Data

How does the site keep personal data secure?
All of our employees are familiar with our security policy and practices and agree to be bound by them as part of their employement contract. The Personally Identifiable Information of our Visitors and Authorized Customers is only accessible to a limited number of qualified employees who are given a password in order to gain access to the information. We audit our security systems and processes on a regular basis. Sensitive information, such as credit card numbers or social security numbers, is protected by specialized third parties using encryption protocols to protect information sent over the Internet. While we take commercially reasonable measures to maintain a secure site, electronic communications and databases are subject to errors, tampering and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to Visitors or Authorized Customers for any such occurrences.

Retaining and deleting personal data

Sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Personal data may be stored for longer periods solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the type of data, as defined in Section 3 above, and the potential need for future use.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

How can Visitors correct any inaccuracies in personal data?
Visitors and Authorized Customers may contact us to update Personally Identifiable Information about them or to correct any inaccuracies by logging into the site or their account, or by emailing our Data Security Officer.

Can a Visitor delete or deactivate personal data collected by the Site?
We provide Visitors and Authorized Customers with a mechanism to delete/deactivate Personally Identifiable Information from the Site's database by unsubscribing links. However, because of backups and records of deletions, it may be impossible to delete a Visitor's entry without retaining some residual information. An individual who requests to have Personally Identifiable Information deactivated will have this information functionally deleted, and we will not sell, transfer, or use Personally Identifiable Information relating to that individual in any way moving forward.

Data location
Electrosmart operates internationally. Personal information collected on our site may be transferred across state and country borders and stored or processed in the United States or any other country in which Electrosmart, its subsidiaries, affiliates or business units maintain facilities for the purposes of data consolidation, storage, and simplified customer information management. By using this website, you consent to any such transfer of information outside of your country of residence. We make every effort to ensure that our website hosting services abide by the Safe Harbor Principles, please visit the U.S. Department of Commerce's website at http://export.gov/safeharbor/.

8. Your Rights

Your principal rights under data protection law relate to:

1. access to personal data held about you
2. the right to rectify or erase personal data held in our system;
3. the right to object to and/or restrict processing of your personal data, including portability;
4. the right to complain to a supervisory authority; and
5. the right to withdraw consent for use of your personal data.

Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

Access - you can access your personal account and profile data when logged into our website or online products and services as appropriate.

Rectify - you have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

Erasure - in some circumstances you have the right to the erasure of your personal data without undue delay. This includes: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

Restrict Processing - In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

Objection to Processing - You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is either (a consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

Complaints - if you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

Withdrawal of Consent - where the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us.

9. Amendments

What happens if the privacy policy changes?
If there are updates to the terms of service' online Privacy Statement, we will post those changes here and update the revision date in this document. If we change our policy in any way that might cause disclosure of Personal Data that a Visitor or Authorized Customer has previously disclosed, we will display this on our site for a one month period following the change.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of any significant changes to this policy by email or through the private messaging system on our website, should we hold that contact information.

Credit

This policy was last updated 22 May 2018