WEBSITE PRIVACY POLICY
Last updated May 6, 2024
This Website Privacy Policy (“Privacy Policy”) describes how INW Manufacturing, LLC and its subsidiaries, divisions and affiliates, hereinafter referred to as INW, uses and protects any information that we may collect from you or that you may give. We are committed to ensuring that your privacy is protected. If you provide us with personal information (“PI” or “personal information” through INW, you can be assured that it will only be used in accordance with this privacy policy (“Policy”).
Specifically, this Policy is intended to provide consumers with information about how INW collects, uses, discloses, retains, and safeguards certain personal information we gather about them such as through the:
Use of our websites, including mobile websites, applications.
Visits to our offices or attendance at one of our events.
Phone and email communications.
Social media interactions, such as through LinkedIn or any other platforms it may utilize.
Viewing our online advertisements or emails.
It also describes options consumers may have concerning their personal information.
Please read this Policy carefully before using the website or submitting personal information to us. By accessing or visiting the website, you indicate your understanding that the collection, use, disclosure, and retention of your personal information is subject to the terms of this Policy. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this Policy, please do not provide us with such information. This Policy does not apply to third-party websites accessible through our website.
WEBSITE VISITORS
Like most website operators, INW collects non-personal information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. INW’s purpose in collecting non-personally identifying information is to better understand how INW’s visitors use its website. From time to time, INW may release non-personal information in the aggregate, e.g., by publishing a report on trends in the usage of its website.
INW also collects potentially personal information like Internet Protocol (IP) addresses. INW does not use IP addresses to identify its visitors, however, and does not disclose such information, other than under the same circumstances that it uses and discloses personally identifying information, as described below.
While we use reasonable measures to protect our website and your information, the Internet is not 100% secure. The measures we use are reasonable for the type of information we collect. We cannot guarantee use of our Site is 100% secure. We encourage you to use caution when using the Internet.
PERSONAL INFORMATION WE COLLECT
As described below, we may collect or have collected in the preceding 12 months the following categories of personal information. We may add to the categories of PI we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy.
Identifiers – such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
Other elements – such as name, signature, characteristics or description, address, telephone number, education, bank account number, credit card number.
Characteristics of protected classifications under California or federal law – such as race, religion, and age.
Commercial information – such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Education information – such as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
Biometric information – such as an individual’s physiological, biological, or behavioral characteristics used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity.
Geolocation data – such as location information while using one of our services.
Audio, electronic, visual, thermal, olfactory, or similar information – such as identifiable information obtained about you from voicemail messages, while speaking with our service representatives, including on the telephone, and captured by video cameras.
Professional or employment-related information – such as information on job applications, information needed during onboarding for payroll and benefits, and information needed for evaluating performance.
Consumer profile – such as inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.
Sensitive Information. Sensitive information means a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.
SOURCES OF PERSONAL INFORMATION
You. We may collect personal information that you provide during your interactions with us, such as through our website, by email, or when you communicate with our associates online, by phone, or at one of our locations. We may also collect information when you attend an event, or participate in a sweepstakes, contest, promotion, or program we sponsor. We collect information when you are an applicant for employment with us and employed by us. We also collect information through certain online tracking tools, such as browser cookies, flash cookies, and web beacons.
Related Entities and Affiliates. We may collect information about you from our related parties and affiliates, including joint ventures.
Social media and related services.
Service providers and contractors. When you obtain products and services from us, we may collect your PI from service provider and contractors who collected information about you that is needed to provide those products and services.
News outlets, social media, surveys, and certain third parties. In the course of performing our services or marketing activities, we or third parties on our behalf may conduct research and other activities resulting in the collection of PI about you.
In each case, INW collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with INW. INW does not disclose personal information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.
DISCLOSURE OF PERSONAL INFORMATION
INW does not sell or share your personal information to third parties. We also do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services. We also do not have actual knowledge that we have sold personal information of minors under age 16.
We may, however, disclose your personal information with services providers and contractors who help us provide the products and services, such as, shipping, payment processing, marketing and advertising, email, text and other communications, applications, sales, business and inventory support, photography, and website, software, platform, cloud, data storage and other technical services.
We may also disclose your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.
Lastly, we may transfer to a third-party personal information as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires of all or part of the assets of our business.
Of the categories of PI noted above, during the past 12 months, we disclosed the following:
Categories of Personal Information Disclosed
Identifiers
Other Elements
Characteristics of protected classifications under California or federal law
Commercial information
Education information
Internet or other electronic network activity
Biometric information
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Consumer profile
Sensitive personal information
Categories of Third Parties to Whom Disclosed
Third parties as directed by you. We will disclose your PI with those third parties to whom you direct.
Our business partners. For example, we might disclose your PI with one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose PI. Where applicable, we encourage you to review each such business partner's privacy statement before signing on with them.
Third parties who perform services on our behalf. For example, we disclose information with certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to disclosure PI on our behalf for these purposes.
Governmental entities, legal service providers. We may disclose your PI in order to comply with the law and in the course of providing our products and services and other business activities of the Company. We may also disclose information if a government agency or investigatory body submits a request.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose PI in preparation for or as part of that transaction.
USE OF PERSONAL INFORMATION
We use the information you provide to:
To present our website(s) and its contents to you.
To provide, support, personalize, and develop our website, and notify you of changes to our website.
To provide you with information that you request from us or that may be of interest to you, including newsletters, event information, and offers and promotions in connection with INW’s products and services.
To provide you with support and to respond to your inquiries and requests.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of INW’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by INW about its website users is among the assets transferred in any other way we may describe when you provide the information.
To help maintain the safety, security, quality, and integrity of INW’s websites, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of INW, our customers, or others.
To carry out our obligations to you and enforce our rights arising from any contracts entered into between you and us.
To manage our recruiting efforts and employment and workforce relationships. These activities include, for example, sourcing and processing employment applications, onboarding employees and contingent workers, and carrying out a range of employments activities relating to the employment relationship, such as compensation, benefits, promotion, discipline, termination, and certain post termination activities.
To comply with our legal, regulatory, and contractual obligations.
To fulfill any other purpose for which you provided the personal information.
For any other purpose with your consent or as otherwise permitted by law.
We will not sell or lease your personal information to third parties unless we have your permission or are required by law to do so.
We would like to send you email marketing communication which may be of interest to you from time to time. If you have consented to marketing, you may opt out later.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click on the unsubscribe link at the bottom of the email.
ACCESS TO DATA
You have the right to request a copy of the information we hold about you. If you would like a copy of some or all your personal information, please contact us at info@inwmfg.com.
RETENTION OF PERSONAL INFORMATION
We will retain your personal information on our systems only for as long as we need to, for the success of the INW site and the programs that support INW. We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information from our live systems. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honor your request.
INW will not delete personal data from logs or records necessary to the operation, development, or archives of the INW site.
When deletion is requested or otherwise required, we will anonymize the data of data subjects and/or remove their information from publicly accessible sites if the deletion of data would break essential systems or damage the logs or records necessary to the operation, development, or archival records of the INW site.
RIGHTS IN RELATION TO YOUR INFORMATION
You may have certain rights under data protection law in relation to the personal information we hold about you. In particular, you may have a right to:
request a copy of personal information we hold about you;
ask that we update the personal information we hold about you, or independently correct such personal information that you think is incorrect or incomplete;
ask that we delete personal information that we hold about you from live systems, or
restrict the way in which we use such personal information (for information on deletion from archives, see the “Retention of personal information” section);
object to our processing of your personal information; and/or
withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).
If you would like to exercise these rights or understand if these rights apply to you, please follow the instructions at the end of this Privacy statement.
INW’S ADDENDUM TO THIS POLICY FOR CALIFORNIA RESIDENTS CAN BE FOUND HERE.
THIRD PARTY LINKS
Our website may contain links to other websites provided by third parties not under our control. When following a link and providing information to a 3rd-party website, please be aware that we are not responsible for the data provided to that third party. This Policy only applies to the websites listed at the beginning of this document, so when you visit other websites, even when you click on a link posted on INW, you should read their own privacy policies.
AGGREGATED STATISTICS
INW may collect statistics about the behavior of visitors to its websites. However, INW does not disclose personal information other than as described in this Policy.
COOKIES
Additionally, information about how you use our website is collected automatically using “cookies”. Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to ‘remember’ you and your preferences, either for a single visit (through a ‘session cookie’) or for multiple repeat visits (using a ‘persistent cookie’). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as ‘first party cookies’), or by third parties, such as those who serve content or provide advertising or analytics services on the website (‘third party cookies’).
We use cookies for a number of different purposes. Some cookies are necessary for technical reasons; some enable a personalized experience for both visitors and registered users; and some allow the display of advertising from selected third party networks. Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the ‘like’ or ‘follow’ button on a post, for example).
Below the different categories of cookies set by INW are outlined, with specific examples detailed in the tables that follow. This includes their name and purpose. Certain cookies are only set for logged-in visitors, whereas others are set for any visitors, and these are marked below accordingly. Where a cookie only applies to specific subdomains, they are included under the relevant header.
Strictly Necessary: These are the cookies that are essential for INW to perform basic functions. These include those required to allow registered users to authenticate and perform account related functions.
Functionality: These cookies are used to store preferences set by users such as account name, language, and location.
Performance: Performance cookies collect information on how users interact with websites hosted on INW, including what pages are visited most, as well as other analytical data. These details are only used to improve how the website functions.
Tracking: These are set by trusted third party networks to track details such as the number of unique visitors, and pageviews to help improve the user experience.
Do Not Track: “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our website is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.
Third Party/Embedded Content: INW makes use of different third party applications and services to enhance the experience of website visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons), or embedded content from YouTube and Vimeo. As a result, cookies may be set by these third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.
NOT INTENDED FOR CHILDREN
Our website is not intended for children under 13 years of age. No one under age 13 may provide any information to or through the website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on our website, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 13, please contact us.
NOTICE TO WEBSITE USER LOCATED OUTSIDE THE U.S.
INW operates in accordance with the laws of the U.S. When you access our website from outside the U.S., we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this website, you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
PRIVACY POLICY CHANGES
Although most changes are likely to be minor, INW may change its Privacy Policy from time to time, and at INW’s sole discretion. INW encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.
CONTACT
Please contact us if you have any questions about our privacy policy or information we hold about you by emailing info@inwmfg.com.
NOTICE TO CALIFORNIA RESIDENTS
Shine the Light. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of INW to third parties for the third parties’ direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we disclosed customer information for the immediately prior calendar year (e.g., requests made in 2024 will receive information regarding 2023 sharing activities). You may submit your request using the contact information in this Policy.
Eraser Law. If you are a California resident under the age of 18, and a registered user of any website where this Policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information in this Policy. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
California Consumer Privacy Act. The section concerning the California Consumer Privacy Act (“CCPA Section”) applies solely to individuals who are residents of the State of California (“consumers” or “you”) as required under the California Consumer Privacy Act, as amended (“CCPA”). This CCPA Section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information we obtain when you access or use the Site, or through other channels including but not limited to visiting one of our locations, phone and email conversations, attending our events, social media interactions on our websites and other third party websites such as social media sites, viewing our emails, or through our authorized services providers.
This CCPA Section supplements and amends the information contained in the Policy with respect to California residents. Any terms defined within the CCPA have the same meaning when utilized within this CCPA Section. All other terms shall have the meaning set forth in the Policy as applicable. The other provisions of the Policy continue to apply except as modified in this CCPA Section.
Please read this CCPA Section carefully before using the website or submitting information to us. By accessing or visiting the website, you indicate your understanding that the collection, use, and sharing of your information is subject to the terms of this CCPA Section.
IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS CCPA SECTION, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.
Right To Know About Personal Information Collected or Disclosed. We generally describe in this Policy our current and practices for the prior 12-months related to the categories of personal information we collect, how we collect and use the personal information, and how we disclose your personal information. In addition to what is described above, as a California resident, you also have the right to request more information regarding the following topics for the preceding 12 months, to the extent applicable:
the categories of personal information,
the categories of sources from which the personal information is collected,
the business or commercial purpose for collecting, selling, or sharing personal information, if applicable,
the categories of third parties to whom the business discloses personal information, and
the specific pieces of personal information the business has collected about you.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to personal information collected on and after January 1, 2022, and to the extent expressly required by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not require a disproportionate effort by us.
Right To Request Deletion Of Your Personal Information. You have the right to request that we delete the personal information we collected or maintained about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers and contractors with whom we disclosed your personal information to also delete your personal information from their records.
There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Some of these instances include, but are not limited to, if we need to:
Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
Help to ensure security and integrity to the extent the use of the consumer's PI is reasonably necessary and proportionate for those purposes.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when the Company's deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which the consumer provided the information.
Comply with a legal obligation.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
Right To Request Deletion Of Your Personal Information. You have the right to quest that INW correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
[Rights regarding sale, sharing, and limiting use of sensitive personal information]
Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate against you for exercising any of your rights under the CCPA, as described above. This includes, but is not limited to: (A) denying good or services to you; (B) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (C) providing a different level or quality of goods or services; or (D) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. It also includes an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.
Submitting Consumer Rights Requests
How to submit. To submit a California Consumer Rights request as outlined in this CA Addendum, please contact the INW by calling us at 877-413-0913 Monday-Friday from 9am–5pm GMT or emailing us at info@inw-group.com. We reserve the right to only respond to verifiable consumer requests to know, delete, or correct. A verifiable consumer request is one made by any individual who is:
the consumer who is the subject of the request,
a consumer on behalf of the consumer’s minor child, or
the authorized agent of the consumer.
What to submit. If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us.
Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the PI we collect from an individual to determine a verifiable request for any other purpose, except as required or permitted by law.
Our response. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
Opt-out preference signals
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.
Authorized Agent. You may authorize a natural person or a business (the Agent) to act on your behalf with respect to the rights under this CA Addendum. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
Questions. If you have questions about this CA Policy, please contact us as described above in the Policy.