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Privacy Policy

Privacy Policy and Requests for Information

This Privacy Policy applies to personally identifiable information collected by Promega Corporation or its affiliates (“Promega”) through this website (this “Website”) or other systems and processes under Promega’s control. Although this Website provides links to third-party websites, such third-party websites are not covered by this Privacy Policy.

Promega assumes no responsibility for the privacy or security of information you provide to any third party through linked websites or any other means.

By using this Website, you agree that you have reviewed and understood our Terms and conditions of Use and this Privacy Policy to your full satisfaction, that you accept and are subject to our Terms and Conditions of Use of Promega Corporation Websites and this Privacy Policy, and that Promega is permitted to use your personal information as set forth below.

Our Privacy Policy is applicable and enforced for the Promega website at www.promega.com and all other websites owned by Promega. It is our intent to comply with the European Union Data Protection Directive 95/46/EC and the Privacy Shield guidelines of the U.S. Department of Commerce. Please refer to the section titled “SPECIAL RULES APPLICABLE TO DATA COLLECTED OR PROCESSED IN THE EUROPEAN UNION” for additional information.

WHAT PERSONAL INFORMATION WE COLLECT AND HOLD

We collect and hold contact information such as name, IP address, physical address, title, department, telephone number, areas of interest and e-mail address. We also collect information submitted by job applicants. You have the option of not identifying yourself or of using a pseudonym when dealing with us but not where this is impractical or where the law or a court order provides otherwise.

HOW WE COLLECT AND HOLD PERSONAL INFORMATION

Collection of personal information: When we collect personal information about you, we do so by making a record of it. We do this when:

  • you communicate with us online;
  • you subscribe to our newsletter;
  • you take part in any trade promotions, testimonials, surveys or focus groups we are involved in conducting;
  • you deal with us in other ways involving a need for personal information to be provided such as trade shows, conferences, seminars, educational symposiums and other similar types of public events.

We may also collect personal information about you from third party sources. We may combine that information with the information we already hold about you. In addition, when you visit our website, we may place a “cookie,” a small computer file, on your computer to help us recognize and serve you better when you return. We keep this information to make it easier for you to utilize our site. You may delete this cookie from your computer without substantially impairing your use of our Website.

WHY WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION

Promega collects, holds, uses and discloses your personal information to process your requests and transactions, offer or furnish additional products and services, personalize the types of information you receive from Promega, assess trends in the use of this Website or purchases of products or services, develop content and functionality that helps us serve our customers’ needs, and improve the service and products we provide. Promega will not use your personally identifiable information in a manner different from that stated at the time of collection without first attempting to notify you via the last email address we have in our records.

We may share your personally identifiable information with third parties that assist us in providing our services, carrying out your account needs or providing you with information about their services that we believe may be of interest to you. If we transfer personally identifiable information to a third party that is acting as our agent, the third party will be required to protect the confidentiality of that information. As we continue to develop our business, we might sell or buy businesses or assets, or Promega might be acquired by another company. In any of those circumstances, personal information in our databases may be included among the transferred assets.

We may use your personally identifiable information jointly with any of our majority-owned subsidiaries so that they may assist us in achieving any of the purposes of use explained above. Promega may also use your personal information to prevent harm or injury, to prevent fraud, to protect our legal interests, to comply with or respond to legal process and to comply with applicable laws.

Resumes submitted by job applicants can be viewed by our human resources department personnel, hiring managers, employees who will be interviewing the candidate and the administrative assistants to these individuals for applicant screening and hiring purposes and for general human resources purposes.

CHOICE

You will have the opportunity to opt out of receiving communications from us when we first request your information. Also, in our e-mail communications you will find instructions for unsubscribing. You can request removal of your personally identifiable information from our databases by contacting us at the address listed below or by using the Privacy Information Request Form. To honor your request, we will need the exact information you want removed and information sufficient for us to identify the type of communication you received from us.

ACCESS OR CHANGE YOUR PERSONAL INFORMATION

You can access, correct, amend or delete the personal information that you have provided by using the login link then selecting “My Profile” in the left column of the Promega website. You will need to enter your username and password.

SECURITY

We have physical, electronic and procedural safeguards to protect personal information we collect online, including the use of passwords to gain access to your information. To protect your privacy and security, you must keep your password confidential. However, even with such measures, no one is able to guarantee that unauthorized third parties will not be able to bypass these measures or otherwise capture information you provide over the internet.

DATA INTEGRITY

We will take reasonable steps to see that the personal information in our systems is relevant for its intended use and is accurate, complete and current.

ENFORCEMENT

Promega will conduct periodic reviews of compliance to verify that this Privacy Policy is accurate, comprehensive, prominently displayed, complete, implemented and accessible. Any employee who violates this Privacy Policy may be subject to disciplinary action.

HOW YOU MAY COMPLAIN ABOUT OUR MANAGEMENT OF PERSONAL INFORMATION

If you wish to complain about a suspected breach of the privacy rules that bind us, you may contact Promega at one of the contact points below. We may ask you to put your complaint in writing and to provide details about it. We may discuss your complaint with our personnel and our service providers and others as appropriate.

Promega will investigate the matter and attempt to resolve it in a timely way. Promega will inform you in writing about the outcome of the investigation. If Promega does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, Promega will inform you that your complaint may be referred to the relevant privacy regulator for further investigation and will provide you with the regulator’s contact details. This paragraph is in addition to that under the special rules applicable to data collected or processed in the European Union set out below.

OUR SHARING OF YOUR PERSONAL INFORMATION OVERSEAS

We may allow your personal information to be shared with those who are in countries other than your own location. Personal information collected via our customer relationship management system is generally stored on servers in Madison, Wisconsin, the United States of America. Other arrangements may apply from time to time, for example:

  • Where we have made a business decision to store our data with a trusted service provider who is in the business of providing data storage and processing services. Examples are those who store and process our email and mobile application data. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency. Where these services are used by us, it is not practical for us to notify you of which country your personal information may be located in;
  • For disclosures between our affiliated companies. Our main business location is in the United States and we do business in a number of countries and some of our affiliated companies may be based in other countries; and
  • When our business which collected your personal information is in a different country to your location.

SPECIAL RULES APPLICABLE TO DATA COLLECTED OR PROCESSED IN THE EUROPEAN UNION

Privacy Shield Principles

Promega complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Promega has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

FTC’s Enforcement and Investigation Powers

Promega is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Definition of “Personal Information” and “Sensitive Personal Information”

"Personal Information" means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

"Sensitive Personal Information" means personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information pertaining to the sex life of the individual.

Onward Transfer/Potential Liability for Third-Party Acts

Promega’s accountability for data it receives pursuant to the EU-US Privacy Shield and subsequent transfer of that data to third parties is detailed in the Privacy Shield Principles. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Promega requires that third parties that receive Personal Information are required to either abide by the Privacy Shield, or provide the same level of privacy protection as is required by the Privacy Shield Principles. Promega may be liable if such third parties fail to meet these obligations and Promega is responsible for the event giving rise to the damage.

Internal and External Procedures for Inquiries and Resolving Complaints

In compliance with the EU–US Privacy Shield Principles, Promega commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with inquiries or complaints regarding this Privacy Policy should first contact Promega at:

Promega Corporation
Privacy/Information Security Manager
2800 Woods Hollow Road
Madison, WI 53711 USA
privacyteam@promega.com

Promega has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to an independent dispute resolution mechanism, the EU Data Protection Authorities (DPAs). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit: http://ec.europa.eu/justice/data-protection/individuals/misuse-personal-data/index_en.htm for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. For additional information about the arbitration process, please visit the Privacy Shield website: www.privacyshield.gov.

Contact Point to Update, Correct Delete or Otherwise Access Personal Information

EU individuals have the right to access personal data about them, and to limit use and disclosure of their personal data. If you wish to request access, to limit use, or to limit disclosure, please email our privacy team at privacyteam@promega.com or send a written request to the contact information provided below.

If at any time after registering for information, your personal information changes or you change your mind about receiving information from us, send us a request specifying updated information or your new choice. Simply send your request to privacyteam@promega.com or telephone or postal mail at the contact information listed below.

Notice of the Data Storage or Processing

Any personal information collected about EU visitors via our websites is processed in the United States by Promega or by a third party acting on our behalf. When you provide personal information to Promega, you consent to the processing of your information in the United States. Our websites are hosted in the United States.

CHANGES TO THIS POLICY

We reserve the right to make changes to this Privacy Policy at any time. If we propose to change this Privacy Policy, we will display at least 2 weeks’ prior notice of the change on our website. Our Privacy Policy will indicate the date it was last updated.

CONTACT POINTS

Please contact us to learn more about our privacy practices or to change your privacy choices:

Promega Corporation
Privacy/Information Security Manager
2800 Woods Hollow Road
Madison, WI 53711 USA
privacyteam@promega.com

Last updated October 31, 2017

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