Privacy and Cookie Policy

BDA Supplemental Privacy Policy for Client-Branded Program Store

BDA understands that you, our Client, may have various privacy obligations with respect to websites where personal information is collected. We strive to provide services in a manner that will help support your efforts towards compliance. For that reason, we have prepared the following supplemental privacy policy for the website(s) that we operate for you to help ensure that storefronts operated by BDA on our clients’ behalf include complete and accurate disclosures about how personal information may be collected, used, and shared in connection with those stores.

The following supplemental privacy policy is intended to be posted on the store(s) we operate for you in addition to your own privacy policy. The intent of this supplemental policy is to help ensure that website visitors receive store-specific information about the data processing activities that take place in connection with the store website. The supplemental privacy policy provides general descriptions about the types of information collected to process store transactions, as well as an overview of the cookies and similar technologies that operate on the website.

Please note, the supplemental privacy policy includes general information only and does not contain jurisdiction-specific disclosures which may be required by privacy laws and regulations, the necessity of which may vary for you. It should not be treated as legal advice. Please review all privacy policies and disclosures with independent legal counsel to ensure that they are sufficient under applicable law.

SUPPLEMENTAL PRIVACY POLICY

Last Updated on 24/10/2023

This Supplemental Privacy Policy provides additional information about the collection, use, and disclosure of personal information in connection with the website at Koch Business Solutions (the “Store Site”), including any related email communications and other services. Bensussen Deutsch & Associates, LLC, together with its subsidiaries and affiliates (collectively, “BDA,” “we,” “our,” or “us”), operates the Store Site on behalf of Koch Business Solutions (“Company”).

us”), operates the Store Site on behalf of Bensussen Deutsch & Associates, L.L.C. (“Company”). This Supplemental Privacy Policy is intended to supplement the information contained in Company’s privacy policy posted on the Store Site. Please carefully review all privacy policies posted on the Store Site or otherwise provided by Company to understand how your personal information may be processed in connection with the Store Site and your related rights in respect of your personal information.

COLLECTION OF PERSONAL INFORMATION

The following categories of personal information may be collected in connection with the Store Site:

Contact details, such as your first and last name, email address, phone number, and mailing address.
Account information, such as the email and account password that you use to establish an online account on the Store Site, your month and day of birth, your employee number, and other information that you may provide when registering for an account.
Transaction information, such as credit or debit card number, billing address, shipping address, and other order details.
Order history, such as records of products and services you have purchased through the Store Site.
Survey responses, such as the information you provide in response to surveys or questionnaires.
Preferences, such as your preferences for receiving communications relating to the Store Site, and details about how you engage with such communications.
Communications, such as the information associated with your requests or inquiries relating to the Store Site, including for support, assistance, or order information, and any feedback you provide when you communicate with customer service.
Online activity information, such as the website you visited before browsing to the Store Site, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Device information, such as your computer or mobile device operating system type and version number , browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state or geographic area.
Inferences based on the personal information collected through the Store Site reflecting your preferences and behavior. For example, we may infer that you are looking to purchase certain products based on your browsing behavior and past purchases.
Other information that may be collected in connection with the Store Site which is not specifically listed here, which will be used as described in this Privacy Policy, in Company’s privacy policy, or as otherwise disclosed at the time of collection

Personal information may be obtained from a variety of sources, including the following sources:

Personal Information You Provide. Your personal information is collected when you voluntarily submit it to us, such as when you fill out a form on the Store Site, register for an account, participate in a survey, or communicate with us.
Personal Information Automatically Collected. BDA, our service providers, and our advertising partners may automatically log information about you, your computer, or mobile device, and your activity over time on the Store Site and other sites and online services, such as the online activity and device information listed above. Like many online services, the Store Site may use cookies and similar technologies to facilitate some of the automatic data collection described above, such as:
- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of promotional campaigns.
- Local storage, which is used to save data on a visitor’s device. We use data from local storage to turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our services, remember your preferences, and measure ad effectiveness.
- Session-replay technologies, which are third-party software used to record a video replay of users’ interactions with the Store Site. The video replay may include users’ clicks, mouse movements, scrolls, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Store Site, understand how users interact with and use the Store Site, and identify areas for improvement.
For more information, please see the Cookie Policy at the bottom of this Supplemental Privacy Policy.
Personal Information Collected Offline. Your personal information will be collected when you call customer service, including a recording of customer service calls for quality assurance and training purposes.
Personal Information Obtained from Third Parties. Your personal information may be collected from third parties, such as Company, our service providers, advertising partners, data analytics partners, or operating systems and platforms. We may merge or combine such personal information with the personal information we collect from you directly or automatically.
Referrals. Users of the Store Site may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.

USE OF PERSONAL INFORMATION

The primary purpose for collecting personal information is to provide the Store Site, to provide related services on behalf of Company, and to operate our business. Personal information may also be used for the purposes set forth below and as otherwise described in this Supplemental Privacy Policy, in Company’s privacy policy, or at the time of collection.

Research and Development. Your personal information may be used for research and development purposes, including to study and improve the Store Site and our business, understand and analyze the usage trends and preferences of users, and develop new features, functionality, products, and services. As part of these activities, we create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
Interest-Based Advertising. We work with third-party advertising companies and social media companies to help us advertise the Store Site. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above in the section called “Personal Information Automatically Collected”) over time across the Store Site and other websites and services, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we or Company shares with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “YOUR CHOICES” section below.
To Comply with Laws and Regulations. Your personal information may be used as necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For Compliance, Fraud Prevention, and Safety. Your personal information may be used and disclosed to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Store Site and our products and services, business, databases, and other technology assets; (b) protect our, your, Company’s, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Store Site; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

DISCLOSURE OF PERSONAL INFORMATION

Your personal information may be disclosed as directed by Company in accordance with Company’s privacy policy. In addition to the specific situations discussed elsewhere in this Supplemental Privacy Policy or at the point of collection, your personal information may also be shared with the following entities or persons in connection with the Store Site:

Related Companies. We may share your personal information with our affiliates, subsidiaries, and other related companies, for the purposes described in this Supplemental Privacy Policy.
Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Store Site or our business. For example, we work with service providers that help us perform website hosting, customer service, maintenance services, database management, analytics, fraud protection, billing, shipping, customer service, and other purposes.
Advertising Partners. We may also share personal information with third parties who partner with us or Company for advertising campaigns or that collect information about your activity on the Store Site for the purposes described in the “Interest-Based Advertising” section above.
Authorities, Law Enforcement, and Others. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency) or for the purposes described above in the section titled “For Compliance, Fraud Prevention, and Safety.”
Business Transaction Participants. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

YOUR CHOICES

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Store Site and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Advertising Choices. You may be able to limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (https://optout.aboutads.info). Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here. Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we or Company work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Store Site currently does not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Access, Correction, or Deletion. You may have additional rights where required by law. For more information and to exercise these rights, please visit Company’s privacy policy.
Opt-Out of “Sales,” “Sharing,” or Targeted Advertising. In some jurisdictions, the disclosure of your personal information to analytics providers or advertising companies who collect your personal information automatically on the Store Site may be considered a “sale” or “sharing” of your personal information. If you would like to opt-out of “sales,” “sharing,” or targeted advertising, please click here: Cookie Preferences. You may also broadcast the Global Privacy Control (GPC) signal. Note that due to technological limitations, if you visit the Store Site from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to the link above to select your preferences or rebroadcast the GPC signal.

SECURITY OF PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.

OTHER SITES AND SERVICES

The Store Site may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

CHANGES TO THIS PRIVACY POLICY

BDA and Company reserve the right, at any time, to modify this Supplemental Privacy Policy. In some cases, such as where required by applicable law, we may notify you about an update by sending you an email, posting a notice about the update on the Store Site, or by other means. In all cases, your continued use of the Store Site following posting or other notification of changes constitutes your acknowledgement of such changes. Please review this Supplemental Privacy Policy periodically to keep up to date on our most current policies and practices.

CONTACT US

If you have any questions about this Supplemental Privacy Policy, please contact us by email at dpo@bdainc.com, or in writing at:

myCompanyStore
c/o BDA
15525 Woodinville-Redmond RD. NE.
Woodinville, WA 98072

COOKIE POLICY

The Store Site uses cookies and similar technologies to provide, improve, promote, and protect the Store Site and as otherwise described below.

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

What is a cookie? A cookie is a small piece of text sent to your browser when you visit the Store Site. It serves a variety of functions, like enabling us to remember certain information you provide to us as you navigate between pages on the Store Site. Each cookie expires after a certain period of time depending on what we use it for. Cookies are useful because they help us make your experience on the Store Site more enjoyable. For example, they allow us to recognize your device (e.g., your laptop or mobile device) so that we can tailor your experience.

Why do we use cookies? We use first-party and third-party cookies for several reasons, such as letting you navigate between pages efficiently, remembering your preferences, keeping you logged into your account, remembering the items you have placed in your shopping cart, letting us analyze how well the Store Site is performing, improving your experience, and helping us advertise products. Some cookies are required for technical reasons in order for the Store Site to operate. Other cookies enable us and the advertising partners we work with to track and target the interests of visitors to the Store Site and across other sites and services. For example, we use cookies to tailor content and information that we may send or display to you and otherwise personalize your experience while interacting with our Store Site and to otherwise improve the functionality of the services we provide. Third parties also serve cookies through our Store Site for advertising, analytics, and other purposes. This is described in more detail below.

What cookies do we use?

Strictly Necessary. These cookies are strictly necessary to provide you with the Store Site and to use some of its features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Store Site, you cannot refuse them without impacting how the Store Site functions. You may be able to block or delete essential cookies by changing your browser settings.
Performance and Analytics, Personalization, and Security. These cookies help us analyze how the Store Site is being accessed and used, enable us to track performance, and secure the Store Site. For example, we use cookies to get insights regarding users and Store Site performance, such as page speed or to help us customize the Store Site for you in order to enhance your experience.
Targeting or Advertising Cookies. These cookies are used to make advertising messages more relevant to you and your interests. The Store Site may use cookies delivered by third parties to track the performance of advertisements. For example, these cookies remember which browsers have visited the Store Site. This process helps us manage and track the effectiveness of marketing efforts.

How do you manage cookies? Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Store Site and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here. If you instead choose to utilize an alternative opt-out option as described in the Supplemental Privacy Policy, please note that such preference must be set on each device and/or browser for which you want them to apply.

You can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by clicking here.

The cookies used on this Store Site, and their purpose, are shown in the following table. You have the right on the Store Site to manage your preferences.