Privacy Notice for California Residents
Last Updated: February, 2023
This Privacy Notice for California Residents supplements the information contained in the general Privacy Policy of Infios GmbH and Infios Management GmbH and their affiliated companies, in particular Infios U.S., Inc., Infios NA, Inc. and Infios NA, LLC (“Infios,” “we,” or “us”), which is incorporated in this privacy notice by this reference. This privacy notice applies to California residents from whom we collect personal information (“consumers” or “you”), including when you visit infios.com, koerber-supplychain.com, highjump.com, mile.com, and profitsystems.com or when you use our other products and services that include an authorized link to this Privacy Policy (“Site”), who reside in the State of California. We adopt this privacy notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and as amended and effective January 1, 2023, the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this privacy notice.
Section 1. Information We Collect
This Site collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include: (i) publicly available information from government records; (ii) deidentified or aggregated consumer information; and (iii) information excluded from the CCPA’s or CPRA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA), or clinical trial data, and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, within the last 12 months Infios’s Site has collected the following categories of personal information from the sources and for the business or commercial purposes described below:
| Category | What We Collect | Source | Business Purposes for Collection |
|---|---|---|---|
| Identifiers (“Identity Data”). |
Name, personal email, business email country, state, providence, personal address, business address, business phone, personal phone, zip code, IP address, job title, job function. For events only: dietary restrictions and credit card information. |
Indirectly through the use of cookies from third parties and form captures. 3rd Parties include Drift, Next Roll, Casale Media, Marketo, Google, Facebook, LinkedIn, Hushly, 6sense, Oktopost,Outbrain, Pubmatic, Taboola, Trade Desk, Triple Lift, Terminus Cvent. Credit card information and dietary restrictions are collected for Tradeshow event registration fees or purposes only and are processed by Cvent. Directly through direct contact from sales team. |
Behavior on our website Buyer intent signals Remarketing purposes Sales follow up Content engagement Tradeshow/Event Registration |
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“Customer Records Data”). *Some personal information included in this category may overlap with other categories. |
Name, personal email, business email country, state, providence, personal address, business address, business phone, personal phone, zip code, IP address, job title, job function. For events only: credit card information; dietary restrictions. |
Indirectly through the use of cookies from third parties and form captures. 3rd Parties include Drift, Next Roll, Casale Media, Marketo, Google, Facebook, LinkedIn, Hushly, 6sense, Oktopost, Outbrain, Pubmatic, Taboola, Trade Desk, Triple Lift Terminus, Cvent. Credit card information and dietary restrictions are collected for Tradeshow event registration fees or purposes only and are processed by Cvent. Directly through direct contact from sales team. |
Behavior on our website Buyer intent signals Remarketing purposes Sales follow up Content engagement Tradeshow/Event Registration |
| Commercial information (“Commercial Data”). | Collected through Terminus and/or 6sense and may include records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Indirectly through 6sense and Terminus. | Data is typically not personal information, rather it is this data is based on a company’s corporate buying signals from recent searches in the marketplace to give an intent value on a specific company. This allow us to do ABM campaigns to those companies or individuals whose buying intent signals are high for products or services we offer. |
| Internet or other similar network activity (“Internet Use Data”). | Browsing history, types of searches completed, interactions with websites or advertisements. | Indirectly through Next Roll, Casale Media, 6sense Outbrain, Pubmatic, Taboola, Trade Desk, Triple Lift and Terminus, and Google Analytics, Google AdWords. | Measure buying intent and current interest in similar service offerings. Advertisement interaction from Google AdWords. |
Section 2. Use and Disclosure of Personal Information
We may also use or disclose the personal information we collect for one or more of the following purposes:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- As described to you when collecting your personal information or as otherwise set forth in the applicable law.
- To service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential, secure, and to use only personal information for the purposes for which we disclose it to them.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Infios’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Infios about the users of this Services is among the assets transferred.
- To enforce or apply agreements;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Infios, users of the Services, or others;
- With your consent.
This data will not be passed on to third parties without your express consent. If the processing of your personal data is based on your consent, you have the right to revoke your consent at any time with the consequence that the processing of your personal data will become inadmissible for the future. However, this does not affect the legality of the processing carried out on the basis of the consent until revocation.
Disclosures of Personal Information for a Business Purpose. We share your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Advertising networks.
- Data analytics providers.
- Operating systems and platforms.
- Social networks.
When we disclose your personal information to a service provider, we enter into a contract with the service provider that describes the business purpose for which your personal information is disclosed and restricts the service provider from using your personal information for any purpose except performing the contract.
In the preceding 12 months, we have disclosed to these third parties the following categories of personal information for a business purpose:
- Identity Data.
- Customer Records Data.
- Commercial Data.
Section 3. Sales of Personal Information
In the preceding 12 months, we have not sold personal information to third parties. Please note that we do not sell the personal information of minors under 16 years under any circumstances, as our website is not intended for users under the age of 16.
Section 4. Your Rights and Choices
If you are a California resident the CCPA and CPRA provide you with specific rights regarding your personal information. This section describes your CCPA and CPRA rights and explains how to exercise those rights.
A. Access Rights and Data Portability Rights. If you are a California resident, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting, using and/or disclosing that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed for a business purpose: disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Whether your information is sold or shared
- The retention period or criteria used for retention
B. Right to Delete & Rectify. You have the right to request that we delete or rectify any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete or rectify (and direct our service providers) your personal information from our records, unless an exception applies. We may deny your request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
D. Right to Opt-Out of Sale and Sharing. You have the right to opt-out of the sale and sharing of your personal information to third parties. Therefore, we offer the ability to opt-out of all advertising cookies and other web technologies for advertising purposes by revoking your consent at any time here:
E. How to Exercise Your Rights. To exercise the rights described above, please submit a verifiable consumer request to us by emailing us at support.sc.msp@koerber-supplychain.com.
- Note that only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
F. Response Timing and Format. We will confirm receipt of a verifiable consumer request within 10 business days and will provide information about how we will process the request.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.
Section 5. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties; provide you a different level or quality of goods or services, including denial of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA or CPRA that can result in different prices, rates, levels, or quality of goods or services. Any CCPA/CPRA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Section 6. Changes to this Privacy Notice
We reserve the right to update or change this privacy notice at any time. When we make changes to this privacy notice, we will post the updated notice on this Site and update the date on which this privacy notice was last updated. The date this privacy notice was last updated is at the top of this page. You are responsible for periodically reviewing this Site and this privacy notice to check for any updates or changes. Your continued use of this Site following the posting of changes constitutes your acceptance of such changes.
Section 7. Contact Us
If you have any questions or comments about this privacy notice or our privacy practices, your choices and rights regarding use of your personal information, or wish to exercise your rights under California law, please contact us using the information found in the imprint. You may also email us at datenschutz.sc@koerber-supplychain.com.