This Privacy Policy explains how SEPAC, Inc. a company organized and existing under the laws of the United States, with registered address at 1580 Lake Street, Elmira, New York 14901, USA (“SEPAC, Inc.,” “we” or “us “), collects, uses, discloses and protects your personal information. This Privacy Policy explains which information we collect, use, process and protect your information and what options our users have with regards to their personal information.

Personal information means any data relating to an identified or identifiable natural person. This policy applies to information we collect when you access or use the SEPAC, Inc. Website, (collectively, SEPAC, Inc.) or otherwise interact with us as described below. We are compliant with applicable laws in the countries in which we operate. By using the SEPAC, Inc. or interacting with us as described below, you confirm that you are aware of this Privacy Policy.

We may amend this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the bottom of this policy, and in some circumstances, we may provide you with additional notice, including, for example, by adding a statement to the homepage of the SEPAC, Inc. or by sending you an email notification. We strongly encourage you to review the Privacy Policy whenever you access or use SEPAC, Inc. to stay informed about our information practices and your privacy rights and choices.

  1. DATA WE COLLECT

We collect information you provide directly to us and we also get some information about you when you interact with SEPAC, Inc. For example, we collect information about you when you register on our website, complete a transaction, fill out a form, use our products and software, or otherwise communicate with us.

The types of information we may collect are as follows:

  • Contact information, namely your email address, name, SEPAC, Inc., address, telephone;
  • Account information such as username and account preferences;
  • All information associated with namely: selected SEPAC, Inc.

When you access or use the SEPAC, Inc., we automatically collect information as follows:

  • Transaction information: We collect information about the transaction you complete via the SEPAC, Inc.
  • Location information: Our website may collect precise geolocation information from your mobile device with your prior consent. If you initially consent to our collection of location information, you may be able to subsequently stop the collection of this information through your device operating system settings. You may also stop our collection of location information by following the standard uninstall process to remove the mobile applications from your device.
  • Device and Log information: We may collect information about the computer or mobile device you use to access the SEPAC, Inc., mobile network information, type of operating system, type of hardware used and the type of browser used. We also log information about your use of the SEPAC, Inc., including access times, pages viewed, IP address, other standard web log data, and the page visited before and after navigating to our websites.
  • Cookies and similar tracking technologies: We may use cookies, pixel tags, web beacons, and other tracking technologies to collect information about you when you interact with the SEPAC, Inc., including information about your browsing behavior on our SEPAC, Inc. For more information on cookies, please see below.
  • Data we collect from third party providers: We use third party providers, including Facebook, Google and others, to collect information about your use of SEPAC, Inc. and enable us to improve how the services work. The information allows us to see the overall patterns of usage on SEPAC, Inc., helps us record any difficulties you have with the services, shows us whether our advertising is effective or not, and allows us to use responses to advertisements to optimize ad performance. Google, Facebook use cookies and other, similar technologies to collect information about the services use and to report website trends to us, without identifying individual End-Users or Visitors to us. See below for more information, or to opt out of these practices:
  • You can learn about Google’s practices by going to https://www.google.com/policies/privacy/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • You may opt-out of Facebook advertising by visiting https://www.facebook.com/settings/?tab=ads/.
  • Software auto-update: Desktop and mobile software products may utilize auto-updating features with your prior consent. If you initially consent to auto-update features, you may be able to subsequently stop the auto-update features through our software products or your device operating system settings.
  1. HOW WE USE YOUR DATA 

2.1. SERVICES

We use your data to operate effectively and provide the best experience with our services.

We use your data to authorize access to SEPAC, Inc., to provide customer support, to manage your account(s) and send you technical notices, updates, security alerts and support and administrative messages. We also use your data to process transactions, to send notices about your transactions and to help prevent potentially prohibited or illegal activities and enforce our user agreements.

With the help of the data you provide us and with linking or combining it with information we obtain from others, we personalize, measure and improve the SEPAC, Inc.

We may also carry out any other purpose for which the data was collected, to the extent such purpose is necessarily for the collection of such information or as otherwise notified in the SEPAC, Inc. at the time of collection.

We use third party services to help us provide our services effectively (e.g., maintenance, analysis, audit, transactions, fraud detection, marketing and development).

2.2. COMMUNICATIONS

We use your email address to get in contact with you, to deliver marketing and promotional offers on behalf of SEPAC, Inc.

You may opt out of receiving promotional communications from us by following the instructions in those communications. You may also opt out of receiving our newsletter or certain administrative emails by contacting Craig Harvey GDPR_Compliance@sepac.com. If you opt out of receiving promotional communications, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

2.3. ADVERTISING

We may target (and measure the performance of) ads to users, visitors and others both on and off our services directly or through a variety of partners. We are using data from advertising technologies on and off SEPAC, Inc., like web beacons, pixels, ad tags, cookies, and device identifiers.

2.4. COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. They are typically stored on your computer’s hard drive.

We use both session and persistent cookies. Session cookies expire when you close your browser. Persistent cookies remain on your computer or mobile device until you erase them, or they otherwise expire. Most web browsers are set to accept cookies by default. You are free to decline most of our cookies if your browser or browser add-on permits but choosing to remove or disable our cookies may interfere with your use and functionality of the SEPAC, Inc. Additionally, we may use certain persistent cookies that are not affected by your browser settings but will use such cookies solely for identity verification and fraud prevention purposes. You may refuse cookies by turning them off in your browser, however, you should be aware that our site, like most other popular sites, may not work well with cookies disabled. For more information about cookies and how to block, delete or disable them, please refer to your browser instructions, or contact us at GDPR_Compliance@sepac.com.

We use third party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using our services. Our service provider(s) is/are contractually restricted from using information they receive from our Site other than to assist us.

  1. HOW AND WHY WE SHARE YOUR DATA

We will only use and disclose your personal information internally in order to:

  • Understand and meet your needs and preferences;
  • Develop new and enhance existing service and product offerings;
  • Manage and develop our business and operations;
  • Carry out any purposes for which we have received your consent; and
  • Meet legal and regulatory requirements.

We may disclose any information we collect about you, whether you are a current or former customer, with law enforcement, data protection authorities, government officials, and other authorities, when:

  • compelled by subpoena, court order or other legal procedure;
  • we believe the disclosure is necessary to prevent physical harm or financial loss;
  • disclosure is necessary to report suspected illegal activity;
  • disclosure is necessary to investigate violations of this Privacy Policy or our Terms of Use.
  • we obtain your consent or at your direction.

We will not sell or rent any of your information to third parties for their own marketing purposes.

3.1. SHARING DATA WITH THIRD PARTY SERVICE PROVIDERS

3.1.1. SEPAC, Inc. Service

We may share some of your data with third party service providers for analytic purposes in order to provide the best user experience. We are sharing data gathered from cookies, device identifiers and usage data with:

  • Facebook SDK to track and examine the use of SEPAC, Inc. Website to prepare reports and analysis;
  • Google Analytics to track and examine the use of SEPAC, Inc. Website in order to prepare reports and analysis.

3.1.2. Communications
We may share your email addresses with third party service providers such as Mailing Services, to send you marketing communications, communicate with you about our services and let you know about our policies and terms. We also use your information to respond to you when you contact us.

3.1.3. Advertising and Analytics (Non-Personally Identifiable Information Only)

We use third-party analytics and advertising providers to help us analyze and improve our services. We are sharing data gathered from cookies and usage data and do not share information that personally identifies you.

We use analytic tool Facebook Pixel to measure the effectiveness of our advertising, to understand your actions on SEPAC, Inc. Website and to optimize our advertising. We also use Google AdWords to connect data gathered from Google AdWords advertising network with actions performed on SEPAC, Inc. Website.

  1. LEGAL BASIS FOR PROCESSING DATA

We collect, use and share data as described above.

We will only collect and process personal data about you:

Where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you).

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer – GDPR_Compliance@sepac.com.

  1. YOUR CHOICES AND OBLIGATIONS

5.1. DATA RETENTION

We retain personal data for as long as necessary to fulfill purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain basic account information and information about performed transactions for at least 5 years after an account is closed.

5.2. ACCESSING AND CONTROLLING YOUR PERSONAL DATA

Regarding your personal data, you have following options:

  • Delete data: You can request deletion of your personal data that we have about you. We will delete the data that we are not legally obliged to keep and since some of the data is necessary to provide SEPAC, Inc. to you, you will not be able to use some of our services after the deletion;
  • Change or correct data: You have the right to request change of incorrect personal data that we have about you;
  • Object to or limit or restrict use of data: You can request that we stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
  • Right to access and/or take your personal data: You have the right to ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You can make a request for any of the above-mentioned actions by sending an email to Craig Harvey GDPR_Compliance@sepac.com.

In relation to all procedures relating to the collection, processing and storage of your personal data, you have the right to appeal to the FTC Data Security (https://www.ftc.gov/tips-advice/business-center/privacy-and-security/data-security).

5.3. ACCOUNT INFORMATION AND ACCOUNT DELETION

You have the right to ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form via email to GDPR_Compliance@sepac.com

If you choose to close your SEPAC, Inc. Account, please contact Craig Harvey at GDPR_Compliance@sepac.com. Your account will be deleted, and your personal data will be erased within 30 days of receiving your request.

We will retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud or abuse. We will retain de-personalized and fully encrypted information after your account has been deleted.

  1. SECURITY

We implement reasonable security practices and procedures to help protect the confidentiality and security of your information, including any non-public personal information.

We protect your information using reasonable physical, technical and administrative security measures, including by limiting access to your information to employees with a need to know such information. To make sure your personal information is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the company.

  1. CONTACT US

If you have any questions or concerns regarding this Privacy Policy, please contact us at GDPR_Compliance@sepac.com

Last updated: June 7, 2018

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