Last Updated: June 13, 2022
1. INFORMATION WE COLLECT
Summary: we collect various categories of personal information in order to meet our contractual obligations and further our business interests.
We collect several categories of Personal Information from a variety of sources while conducting our business, including those listed below. Personal Information means information which identifies or is reasonably capable of being associated with a particular natural person. To the extent permitted by applicable law, Personal Information does not include information that has been deidentified, pseudonymized, aggregated or anonymized.
1.1. Interactions with Sites and Us. When you visit Sites, you may choose to provide Personal Information and other information. This information may include your name, email address, phone number, picture, postal address, birthdate, gender, and other identifying information. We collect Personal Information when you register interest with us, make an order, register for a warranty, contact our support centers, contact us for information, sign up for newsletters and updates, or open an account. In most cases, you provide this information to us directly; in other cases, your employer or an organization you represent may provide this information, or it may be provided by a vendor with whom you have contracted. You may also provide Personal Information when you meet us or our partners in person at events and other locations. We also collect email addresses of people who communicate with Keter via phone, email, messenger services or other social media platforms.
1.2. Service Providers. We collect Personal Information and other information about individuals associated with service providers that we engage, such as name, address, email address, telephone number, company name and title.
1.3. Job Applications. We collect Personal Information and other information relating to employment candidates, including name, address, email address, telephone number, and information on resumes. We may also collect information through notes on meetings, standardized tests, reports, references, interviewer impressions and such industry standard data, as well as data made publicly available or available to us on social networks.
1.4. Device and Browser Information. When you visit the Sites, we may collect technical and behavioral information such as your Internet Protocol (IP) address, your uniform resource locators (URL), the domain name of your Internet service provider, the operating system of your browsing device, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, which pages you visit and how long you spend on each page, methods used to browse away from a page, and your geographic location. See Section 4 for information about cookies.
1.5. Social Media and Other Sites. In some cases you may be able to access the Sites or our services through login credentials of a designated third party website or service (each a “Third Party Account”), such as Facebook. Doing so will enable you to link your Keter account and your Third Party Account. If you choose this option, then you will be required to approve the connection as well as the provision of information (which may include Personal Information and other information, such as your profile picture, gender, birthdate, headline, summary that appears in the profile, friends’ lists, previous positions and organizations), that we obtain from your Third Party Account. Any data submitted to any Third Party Account, even on and through Keter services, is managed directly by such third party and is not the responsibility of Keter. The Third Party Account may connect your visit to the Sites with your Personal Information.
1.6. Other Information. Keter may also collect Personal Information through the use of CCTV cameras. This may consist of video images of you in the public spaces at Keter sites and third party sites where Keter may sponsor or participate in an event, as well as records of your entrances and exits of the Keter sites, buildings and office floors. It also includes identity verification systems and data. We may not always be aware of the nature of the information collected through our services (for example, through our CCTV systems), and such information may inadvertently include sensitive or special categories of Personal Information, but we do not knowingly collect such data about our customers, members, site visitors etc. We may also obtain Personal Information about you from third parties, including entities that direct you to or are accessible via the Sites, and business partners.
You are not required to provide any Personal Information to Keter; however, we require certain information in order to perform contracts, such as a sale or purchase, or to provide any services and products. If you choose not to provide us with certain information, we may not be able to provide you with some or all of the services or fulfill your order for products.
2. PURPOSES AND USES OF PERSONAL INFORMATION
Summary: we use Personal Information to meet our obligations, protect and enforce our rights and manage our business.
We use Personal Information to provide and improve our services to our customers and others and meet our contractual, ethical and legal obligations, including for example:
- Carrying out our obligations arising from any contracts entered into between you or your employer or organization and Keter and/or any contracts entered into with Keter;
- Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract:
- Providing you with the information, products and services that you request from Keter;
- Administering your account with Keter including to identify you and authenticate your identity;
- Verifying and carrying out financial transactions in relation to payments you make in connection with products and services;
- Notifying you about changes to our service and products;
- Providing you with technical assistance and other related information about the products;
- Contacting you to give you commercial and marketing information about events or promotions or services and products offered by Keter, including in other locations;
- Soliciting feedback in connection with your use of the services and the products purchased;
- Tracking and analyzing use of Keter Sites, facilities and services to enable us to analyze and optimize them;
- Replying to your queries, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
- Sharing data across the Keter group and its service providers, including across multiple locations internationally, in order to effectively manage our business;
- Enabling us to evaluate job applicants;
- Analyzing transactions and communications for fraud and crime prevention and to protect our staff, property, site visitors and third parties;
- Compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for crime prevention and prosecution;
- If necessary, we will use Personal Information to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, to comply with our legal obligations and to take any action in any legal dispute and proceeding;
- For security purposes and to identify and authenticate your access to our facilities and services;
- We collect Personal Information of our clients’ personnel which will be used for the purposes set out above;
- To detect and prevent damage to Keter, its employees and third parties;
3. SHARING PERSONAL INFORMATION WITH THIRD PARTIES
Summary: we may share Personal Information with our affiliates, business partners, service providers, and other third parties.
Your Personal Information and other information may be shared with others as follows:
3.1. Affiliates. We may share Personal Information with our affiliates, including our subsidiaries (whether wholly or partially owned by Keter) (“Affiliates”), which may be located in the European Union, Israel, Canada and elsewhere, for their own marketing and other purposes.
3.2. Third Parties and Marketing Purposes. We may share Personal Information with third parties, such as business partners, for joint marketing purposes or our business partners’ (or our own) marketing purposes.
3.3. Third Parties and Non-Marketing Purposes. We may share Personal Information with third parties in a variety of circumstances for non-marketing purposes. We take steps to ensure that these third parties use Personal Information only to the extent necessary to perform their functions. These third parties include business partners, service providers, suppliers, agents and sub-contractors. They assist us in providing the products we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks. These third parties also include analytics and search engine providers that assist us in the improvement and optimization of our Sites and our marketing. They also include service providers who may help prevent fraud, protect Keter, its staff and its property, and assert our rights.
We periodically add and remove third party providers. At present, third party providers to whom we transfer Personal Information include entities engaged in the following types of services, among others:
- Website analytics;
- Digital marketing agencies;
- Document management and sharing services;
- Customer ticketing and support
- On-site and cloud-based database services
- Vendor and customer interface
- CRM software
- ERP software
- Data security, data backup, and data access control systems;
- Project management system;
- Call center systems;
- Customer service providers for Keter products;
- Recruiting and applicant management software and partners.
- Our lawyers, accountants, and other standard business software and partners.
4. DEVICE DATA COLLECTION AND COOKIES
Summary: we place, and may allow third parties to place, cookies on your device. We do not place non-necessary cookies without your consent. You can control non-necessary cookies through a cookie preference tool on some of our Sites and other methods.
When you access or use our Sites, we use, and may allow third parties to use, cookies which store certain information on your browsing device. Cookies identify the device from which you connect and in some cases could be used to identify you. We use different types of cookies. Different cookies are kept for different periods. Session cookies are used to keep track of your activities online in a given browsing session; these cookies generally expire when the browser is closed but may be retained for a period on your device. Permanent cookies remain in operation even when you have closed the browser.
Some cookies are necessary as they are required for the operation of the Sites, such as cookies that enable you to log into secure areas. You cannot opt-out of necessary cookies. We will not place non-necessary cookies on your device without your consent. You can consent to cookies through the cookie preference tool available on some of our Sites, and you can withdraw consent using the tool. The cookie preference tool is device and browser specific. If you delete or clear cookies or change devices or browsers, you will need to reset your cookie preferences using the tool. In addition, you may use your browser settings to delete and reject cookies. However, erasing or not consenting to some types of cookies, through the tool or your browser settings, may limit your experience on the Sites and the services we are able to offer.
5. RIGHTS AND CHOICES
5.1. Opt-Out of Marketing and/or Sharing with Affiliates and Third Parties. If you wish to opt-out of receiving any marketing solicitations from us, and/or from our sharing your Personal Information with Affiliates and/or third parties for their own marketing purposes, please contact us at the email or postal address listed in Section 12. Even if you opt-out, we may still use and share the information we collect for non-marketing purposes.
5.2. Unsubscribe from Emails. Any marketing emails we send will include an automated way for you to opt out (unsubscribe) from that marketing email distribution sent by us. To unsubscribe, please follow the instructions in the email you receive.
5.3. Opt-Out of Online Tracking. See Section 4 for instructions on how to withdraw consent for non-necessary cookies, including cookies used for third-party advertising, if you previously consented using our cookie preference tool and other methods.
5.4.1. Categories of Personal Information: To the extent permitted by applicable law, Personal Information does not include information that is publicly available. We collect the following categories of Personal Information listed in the CCPA, and may have collected any or all of this information in the preceding 12 months: (a) identifiers such as name, postal address, email address, account name, social security number, driver’s license number and passport number; (b) categories described in Cal. Civ. Code § 1798.80(e), such as telephone number, insurance policy number, education, employment, bank, credit card number or other financial information and medical information; (c) characteristics of protected classifications under California or federal law, such as race, national origin, age over 40, disabilities, sex, marital status and military status; (d) commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; (e) biometric information; (f) internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet web site, application, or advertisement; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory, or similar information; (i) professional or employment-related information; (j) education information, defined as information that is not publicly available personally identifiable information (as defined in 20 U.S.C. § 1232g, 34 C.F.R. Part 99); and (k) inferences drawn from any of the information identified above to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
5.4.2. Sources and Use of Personal Information. We collect Personal Information from the sources listed in Section 1. We use Personal Information for the business and commercial purposes listed in Section 2.
5.4.3. Right to Know. To the extent permitted by law, you have the right to request that Keter 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 as described below, we will disclose to you: (a) categories of your Personal Information we collected; (b) categories of sources of your Personal Information; (c) business or commercial purposes for collecting your Personal Information; (d) categories of third parties with whom we shared your Personal Information; and (e) specific pieces of your Personal Information we collected.
5.4.4. Request to Delete. You have the right to request that Keter delete Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request as described below, we will delete your Personal Information from our records, unless an exception applies under applicable law. For example, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (a) complete the transaction for which we collected the Personal Information, provide a good or 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; (b) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (c) debug products to identify and repair errors that impair existing intended functionality; (d) protect our legal interests, to defend our rights in a case of potential, threatened, or actual litigation, and to enforce our rights; (e) comply with a legal obligation and (f) fulfill internal and lawful uses that are compatible with the context in which you provided the information.
5.4.5. Exercising Your Rights to Know and Delete. To exercise the rights described above, please submit a verifiable consumer request to us by visiting the Do Not Sell My Personal Information link on our Sites or calling us toll free at 1-888-374-4262. 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 only exercise your Right to Know right twice within a 12-month period. The verifiable consumer request must (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and (b) 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. We do not charge a fee to process or respond to your verifiable consumer request unless it 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.
5.4.6. Disclosure and Sale of Personal Information. We may disclose Personal Information for business purposes and/or to the third parties listed in Section 3. We do not sell Personal Information to third parties for monetary compensation. The use of certain cookies placed by third parties on our Sites as described in Section 4 or the sharing of Personal Information in other transactions we engage in with third parties not involving monetary consideration may be considered a “sale” under CCPA. If you wish to opt-out of having your Personal Information sold to third parties, please visit the Do Not Sell My Personal Information Link on our Sites or call us toll free at 1-888-374-4262. We will not authorize third party cookies for your device unless you consent in our cookie preference tool. If you consent and wish to later withdraw your consent, please use the cookie preference tool to disable these third party cookies in order to fully exercise your CCPA opt-out rights. The cookie preference tool is device and browser specific. If you delete or clear cookies or change devices or browsers, you will need to reset your cookie preferences using the tool. You may use an authorized agent to submit an opt-out request, provided the agent has your signed permission.
5.4.7. Notice of Financial Incentives. We may offer you a program, benefit or other offering related to the collection of Personal Information, which may be considered a financial incentive under CCPA. If you wish to withdraw from the benefit, please contact us at the email or postal address listed in Section 12. We will not reduce the value of any incentive you previously received from us if you do so, or discriminate against you if you exercise any of your CCPA rights after signing up for the benefit. Each financial incentive related to submission and use of Personal Information is based upon our reasonable but sole determination of the estimated value of such information, which takes into consideration, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under the CCPA. You will be notified of the Personal Information you are required to submit at the time you sign up for the incentive. For example, we may offer a one-time ten percent discount code if you provide your email address and sign up to receive our newsletter. The use of the discount code is subject to terms and conditions displayed in our Terms of Sale. You may unsubscribe from the newsletter for any reason by contacting us at the email or postal address listed in Section 12, or using the unsubscribe option at the bottom of the newsletter email. Even if you unsubscribe, you can still use the discount code (subject to its terms and conditions) and exercise all of your CCPA rights as described above.
5.5. California Customers. The California “Shine the Light” law requires some businesses to respond to requests from California customers about the disclosure of certain personal information to third parties for third party marketing purposes. Alternately, such businesses may adopt a policy of not disclosing such personal information to third parties for marketing purposes if a California customer has opted-out of such information sharing. We have adopted an opt-out policy. In order to opt-out, please contact us at the email or postal address listed in Section 12. In addition, see the instructions above regarding the sale of Personal Information.
5.6. Nevada Consumers. We do not sell Personal Information to third parties for monetary compensation. However, you may direct us not to make any monetary sale of Personal Information by contacting us at the email or postal address listed in Section 12.
6. DATA RETENTION
Summary: we retain Personal Information according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.
Keter will retain Personal Information in accordance with our data retention policy, as long as required to provide the services and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain Personal Information to meet any audit, compliance and business best-practices.
7. SECURITY AND STORAGE OF INFORMATION
Summary: we implement, enforce and maintain security measures to protect Personal Information.
Keter implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Information. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, we may encrypt data. Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur. Similarly, we cannot guarantee the privacy of information you transmit over the Internet or that may be collected in transit by others, including contractors that provide services to us.
8. UNITED STATES POLICY
You must be at least 18 years old, or the age of majority to enter into a contract, whichever is older, to use our Sites. If you are under that age, do not register or attempt to register for any of the Keter services or send any information about yourself to us. If we learn that we have collected or have been sent Personal Information from a minor, we will delete that Personal Information as soon as reasonably practicable without any liability to Keter. If you believe that we might have collected or been sent information from a minor, please contact us at firstname.lastname@example.org.
10. OTHER WEBSITES AND LINKS
Our Sites may contain links to other websites. We are not responsible for the information collection or privacy practices of other websites. You should consult the privacy policies of other sites before you visit those sites or provide any information to those sites.
12. CONTACTING US