VERSION 4, LAST REVIEWED DATE 06/02/2020, DOCUMENT OWNER: IT SECURITY COMMITTEE
THE TYPES OF INFORMATION WE COLLECT ABOUT YOU
When you enter and browse the Site, we may collect information you provide to us and information through technology. ACS may retain any information collected through the Site for an indefinite period of time.
In order to obtain access to certain information or materials provided via the Site, you may have to provide information that we collect and store in a way that allows us to relate it to you personally, including but not limited to your:
• [Name and contact information (e.g., email address, mailing, business, or residential address, phone number, and fax number).]1
• Username and password.
• Social media account information.
We refer to such information as personal information. Additionally, we may collect and retain a record of all communications with you.
We may collect certain information provided to us by third parties such as information for identity verification purposes, credit checks, financial or credit bureau information (such as a business owner’s credit score, credit history and bank account information) and publicly-available information.
We may use the information above for various purposes, including but not limited to:
• Account registration, including for identity verification purposes
• Placement and fulfillment of an order, opportunity registration, and participation in rebate programs
• Responding to requests for information, quotes, services, and samples
• Providing customer service and support
• Providing webinars and training activities
• Sign-ups for or subscriptions to products and services, newsletters, promotional activities and other opportunities, contests, sweepstakes, and surveys
• Responding to job postings
• Responding to questions or requests for information about ACS and its affiliates
We may also collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site (an IP address is often associated with the portal through which you enter the Internet). At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site.
The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect and process information on our behalf. We may also use these technical methods in emails that we send our Site users to determine whether such users have opened those emails and/or clicked on links in those emails. We may collect the information from the use of these technical methods in a personally identifiable form.
We may also collect information about how you use the Site such as general demographic information, viewership data and other anonymous information (e.g., what content is viewed, related transfer rates, length of viewing, which pages are viewed, from which websites end-users came to our Site, IP address(es), browser type and other information relating to the device through which the Site is accessed, and, for certain Service or product offerings selected by you, other information relating to the device through which the Site or Service are accessed).
We may also collect non-personal information and data in a form that does not permit direct association with any specific individual, including anonymous information and aggregate data. We may collect, use, transfer, and disclose non-personal information for any purpose permitted by law.
OUR DISCLOSURE AND USE OF YOUR PERSONAL INFORMATION
• To conduct business with our affiliates and subsidiaries, consultants, and service providers, including any or all of the ACS portfolio companies
• To improve the Site and our products and services
• To deliver and support our services and products
• To carry out transactions you have requested
• For auditing, data analysis, and research
• To send you information about the Site, products and services, promotional activities, opportunities and marketing information, product safety information, and your transaction status
• To provide information to our lenders or other financial partners
• To protect the safety and security of tangible or intangible property that belongs to us, to you, or to third parties
• To potential or actual acquirers or successors (including their advisors) in the event that ACS, or any portion of our assets or businesses, is acquired by or merged with another entity (whether to an affiliate or a third party)
• To enable contractors, security consultants, customer service providers (e.g., information technology or human resources consultants or service providers), credit bureaus, and collection agencies to perform certain functions on our behalf, including to report or ask about your financial circumstances, and to report or collect debts you owe
• To regulatory authorities, courts, and government agencies to comply with applicable laws, regulations, legal orders, and government requests, including subpoenas and/or Service of process. • To service providers, regulatory authorities, and governmental agencies to detect and prevent fraud or criminal activity, and to protect the rights of ACS and/or others
ACS will not sell your personal information.
COOKIES AND LOCATION BASED SERVICES
“Cookies” are small text files that are stored by your web browser on your computer’s hard drive. They allow websites to store such things as user preferences. Websites generally use both session cookies and persistent cookies. Session cookies are temporary cookies that expire (and are automatically erased) when you close your browser. Persistent cookies usually have an expiration date far into the future and thus stay in your browser until they expire, or until you manually delete them. While some cookies are strictly necessary cookies to use our website or required for the performance of certain functionalities of our website, other cookies are used for marketing purposes.
The cookies used on our Site are categorized as follows:
• Strictly necessary cookies
• Performance cookies
• Functionality cookies
Strictly necessary cookies – these allow you to move around the Site and use essential features like secure areas for gated content. Without these cookies, we may not be able to provide services you have asked for. Please note that these cookies do not gather any information about you that could be used for marketing or remembering where you have been on the Internet. We use these strictly necessary cookies to enable you to submit information via online forms, such as registration forms. Accepting these cookies is a condition of using the full functionality of the Site, so if you prevent these cookies, we can’t guarantee your use of our Site or how the security on our Site will perform during your visit.
Performance cookies – these collect information about how you use our Site, e.g. which pages you visit, and if you experience any errors. These cookies are used to help us improve how our Site works, understand what interests our users, and measure how effective our content is. We use performance cookies to provide anonymous statistics on how our Site is used. Some of our performance cookies are managed for us by third parties. Please see the information on our use of Google Analytics. However, we do not allow the third party to use the cookies for any purpose other than those listed above. Accepting these cookies is a condition of using the full functionality of our Site, so if you prevent them, we cannot guarantee how our Site will perform for you.
ACS web servers automatically record information that your browser sends whenever you visit the Site. The server logs may include information such as your web request, IP address, browser type and language, dates, times and cookies.
We may engage third parties to track and analyze Site activity. These third parties may place cookies or web beacons to track user activity on our Site. We use the data collected by such third parties to help us administer and improve the quality of the Site, analyze usage of the Site, and provide a more enhanced user experience on the Site, such as personalizing and delivering relevant content based on user activity on the Site
ACS and its partners may provide certain features as part of the Service that rely upon device-based location information. To provide such features or services, ACS may collect, use, transmit, process and maintain your location data, including the real-time geographic location of your device. Such information may include but is not limited to device ID, device type, and real-time geographic location of your device at the time of your request.
Our Site uses Google Analytics, a web analysis service provided by Google Inc., (“Google”). Google Analytics uses “cookies”. The information generated by the cookie regarding your use of the Site is normally transferred to a Google server in the USA, and is stored there. As the IP anonymize function is activated on our Site, your IP address will, within Member States of the European Union or other contracting states of the Agreement on the European Economic Area, first be shortened by Google. Only in exceptional cases will Google transfer the full IP address to a Google server in the USA, and will shorten it there. On behalf of the operator of this Site, Google will use this information in order to analyze your usage of our Site, to compile reports on website activities, and to provide further services to the website provider relating to the usage of the Site and the Internet. The IP address transferred by your browser within the framework of Google Analytics will not be combined by Google with other data. In case you prevent the storage of cookies by setting your browser software accordingly, you may possibly not be able to fully use all features on this Site. Furthermore, you can prevent collection by Google of the data generated by the cookie and relating to your use of the Site (including your IP address), as well as processing of these data by Google, by downloading and installing the browser plugin provided under the following link: https://tools.google.com/dlpage/gaoptout?hl=en
Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
At end of session
Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
At end of session
Used by Google Analytics to throttle request rate.
DO NOT TRACK
We do not use technologies that respond to ‘Do-Not-Track’ signals communicated by ‘Do-Not-Track’ signals communicated by your internet browser. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.
END-USER GENERATED CONTENT
We take reasonable physical, technical and administrative measures designed to protect the security of your personal information. Despite our efforts, no data security measures can guarantee the security of any information you disclose online. We do not make any warranty, express, implied or otherwise, that we will be able to prevent loss, misuse, unauthorized access to, or alteration of any personal information you provide to us. We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personal information. You use our Site and send us information at your own risk.
As a default position, we will only retain personal data for any statutory retention period, then a reasonable period (if any) necessary for the above purposes. This is subject, for example, to any valid opt-out, user request, or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights which is affected.
ACS does not permit children under the age of 18 to register on the Site or use any of its functionality for which registration is required. ACS does not knowingly collect the personal information of children under age 18. If you are under 18 years of age, you may not use the Site, and you should not provide any information to ACS. If ACS determines that a minor under the age of 18 is using the Site or has provided information to ACS, ACS will terminate the account, the minor’s use of the account, and delete all related information. In addition, if you are a minor under the age of 18 and wish to remove any content you have provided on the Site, please send an email to info@ACS-power.com requesting removal of any content provided.
If you are a California resident, you have the right to request that we disclose to you or delete certain information about our collection and use of your personal information. Once we receive your request and verify your identity, we will disclose such information to you or delete the same, unless a legal exception applies. For example, we may deny your deletion request if retaining the information is necessary for us or our providers to complete the transaction for which we collected the personal information, provide a 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.
To exercise the rights described above, please submit a request to us by either:
• Calling us toll-free at 1-844-920-9749.
• Emailing us at email@example.com.
Your request must:
• Provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person.
• Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with non-public personal information if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you. We will use the information provided in a request solely to verify your identity or authority to make the request.
CALIFORNIA’S SHINE THE LIGHT LAW
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our Site users who are California residents to request and obtain from us a list of their personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not share any personal information with third parties for their direct marketing purposes.
GOVERNING LAW AND FORUM
CONTACT ACS WITH ANY QUESTIONS:
American Construction Source
1311 E. Woodhurst Drive
Springfield, MO 65804
Version Date Author Notes 1.0 2/6/2020 Trent Waterhouse Policy created
Added Homewood websites to Scope 3.0 4/27/2020 STB Major rewrite by STB
Added language on information sharing across ACS.