Ordergroove, Inc. (“Ordergroove”, “we,” “us,” or “our”), is committed to protecting and respecting your privacy. Ordergroove’s Relationship Commerce Cloud™ (the “Service”) offers a comprehensive suite of capabilities that simplifies the consumer ordering and reordering experience by enabling omnichannel retailers and brands to practice and achieve Relationship Commerce – across any and every channel.
Where Ordergroove collects or receives Personal Information about Visitors directly from Visitors, we will explain the purposes for which we collect and use such Personal Information, the types of third parties to which we disclose that information, and the choices and means, if any, we offer you for limiting the use and disclosure of Personal Information about you. This explanation will be provided as soon as practicable and, in any event, before we disclose your Personal Information or use such information for a purpose materially different than that for which it was originally collected or processed.
Where Ordergroove collects or receives Personal Information about Visitors from our Clients, which occurs when we are acting as a provider of Services to our Clients on Client Sites, we do so as a processor (under GDPR) and/or as a service provider (under CCPA) of Personal Information on behalf of our Clients. We will use such information in accordance with the notices provided to Visitors by our Clients and in accordance with the choices Visitors made with respect to such Personal Information, as communicated to us by our Clients.
Collection and Use of Information Through Our Website
Visitor- and Client-Provided Information: When Visitors visit our Website, we may collect certain types of Personal Information about you that you submit voluntarily. This information may include your name, address, email address and telephone number. This information may also include the communication content and metadata associated with the communication. This may occur when you send us an email, submit a website form requesting information about Ordergroove or our Service, use an on-site live chat service, or otherwise communicate with us. In addition, if you are accessing the Website or Service on behalf of a Client, you may provide certain information in order to manage the Client’s account, for example your name, email address and password. Our legal bases for processing this information is your consent, the performance of a contract between you and us and our legitimate interests, namely the proper administration of our Website and communications with Visitors.
We also collect certain Personal Information from Clients in order to manage their accounts, including credit card numbers and associated billing information. We refer to this information as “Billing Information”. Our legal basis for processing this information is the performance of a contract between our Clients and us.
How We Use Information We Collect Through Our Website (i.e. from Visitors visiting our Website): We use information that we collect through our Website to respond to your requests, resolve problems, improve the quality of the Website and Service, and market our products or services and those of third parties to you. We use Billing Information from our Clients only for purposes of authentication and to process Client payments. With respect to any information that we collect or receive, we may also anonymize such information by removing identifying characteristics (if any) and aggregating it with the information of others. We may use such information to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction. We may use all information we collect through our Website to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes.
Collection and Use of Information Through Client Sites
Visitor- and Client-Provided Information: We may process Personal Information about Visitors that is provided to us by our Clients that Visitors provide voluntarily when they visit Client Sites and use our Service. This information may include your name, email address, mailing address, billing address, credit card details and telephone number. This may occur when you register for services on our Client Sites. We may also process information relating to transactions that you enter into with our Clients on our Client Sites, including purchases of goods and services. This transaction information may include transaction details, such as purchase and shipping information, dates of purchase and purchase history. This transaction information may also include subscription information, including which goods and services are subscribed for, and subscriptions history, and credit card numbers and associated billing information. Our legal basis for processing this information is the legitimate interests of our Clients (data controller).
Automatically-Collected Information. We may process additional information about you that is provided to us by our Clients that is collected automatically when you visit Client Sites and use our Service. This additional information may include some of the same information we automatically collect about you when you visit our Website, as well as products or services you viewed. Our legal basis for processing this information is the legitimate interests of our Clients (data controller).
How We Use Information We Collect Through the Service: We use information about you provided to us by our Clients that you provide voluntarily and that is collected automatically when visiting Client Sites to provide our Service to our Clients; respond to your requests, resolve problems, improve the quality of the Service, and market our products or services and those of third parties to you. With respect to any information that we collect or receive, we may also anonymize such information by removing identifying characteristics (if any) and aggregating it with the information of others. We may use such information to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction. We may use all information about you provided to us by our Clients that is collected when visiting Client Sites to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes.
(Disclosing Personal Information to Third Parties)
Ordergroove will offer you the opportunity to choose whether your Personal Information is to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by you.
Ordergroove does not request or knowingly receive or collect Sensitive Personal Information. Nonetheless, if at any point in the future Ordergroove receives or collects Sensitive Personal Information (defined below) about you, Ordergroove will not process such information about you for purposes other than those for which the information was originally obtained or subsequently authorized by you unless you explicitly consent to the processing, or as required or permitted, or where not prohibited by law or regulation. “Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, biometric data where processed to uniquely identify a person, any information that concerns medical or health conditions or sex life, or information relating to the commission of a criminal offense.
Opting Out of Marketing Communications
If you receive marketing or promotional emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “Contact Us” section.
ACCOUNTABILITY FOR ONWARD TRANSFER
We use model contractual clauses and other mechanisms approved by the European Union and Switzerland, respectively, for transfers of Personal Information from the European Economic Area (“EEA”) and Switzerland.
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. Taking into account the risks involved in the processing and the nature of the Personal Information we process, Ordergroove maintains appropriate administrative, technical and physical safeguards to protect Personal Information in our possession against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Information.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Information has been compromised, please contact us as set forth in the “Contact Us” section.
We have a security incident response program designed to promptly respond to and escalate any potential privacy or security incident. If we learn of a security incident, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
DATA INTEGRITY AND PURPOSE LIMITATION
We seek to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. Ordergroove will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current and otherwise reliable in relation to the purposes for which the information was obtained or is used by us for as long as we retain possession of such information. Ordergroove’s personnel have a responsibility to assist us in maintaining accurate, complete and current Personal Information. When acting as a provider of the Service to our Clients on Client Sites, Ordergroove endeavors only to process Personal Information that is relevant to the Service, and for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified.
ACCESSING AND CONTROLLING YOUR INFORMATION
EU data protection law makes a distinction between organizations that process Personal Information for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). If you have a question or complaint about how your Personal Information is handled, these should always be directed to the relevant controller, since the controller has primary responsibility for your Personal Information.
(For Visitors to Client Sites) When we are acting as a provider of our Service to our Clients on Client Sites, Ordergroove is a processor in respect of Personal Information about Visitors to Client Sites that Clients provide us. Ordergroove has no direct relationship with Visitors to Client Sites, and any such Visitors who seek to access or who seek to correct, amend, delete, or restrict their Personal Information should direct their requests to our relevant Client which has transferred such Personal Information to Ordergroove for processing. We will assist our Clients in fulfilling their obligations under applicable law to respond to such requests by individuals regarding their Personal Information.
Please note that while any deletions will be reflected in active user databases (as updated within a reasonable period of time), Ordergroove may retain all Personal Information for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
We may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
RECOURSE, ENFORCEMENT AND LIABILITY
Ordergroove encourages you to raise questions about our processing or disclosure of your Personal Information by contacting us, as set forth in the “Contact Us” section below.
The Website may contain links to other websites that are not owned or controlled by us. When you click on such a link, you will leave our Website and go to another site. During this process, another entity may collect Personal Information from you. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
In compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any Personal Information from anyone under 13 years of age. Our Website and the Service are all directed to people who are at least 13 years old or older.
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Supplemental Privacy Notice for California Residents
Information We Collect
Our Website and our Service (on Client Sites) collect Personal Information. In particular, our Website and our Service have collected the following categories of Personal Information from consumers within the last twelve (12) months:
|Category||Examples||Collected on the Website?||Collected on the Service (on Client Sites)?|
|A. Identifiers||A real name, Internet Protocol address, email address, or other similar identifiers.||YES||YES|
|B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.||YES||YES|
|C: Protected classification characteristics under California or federal law||Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO||NO|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO||YES|
|E. Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO||NO|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES||YES|
|G. Geolocation data||Physical location or movements.||YES||NO|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||NO||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO||NO|
|K. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO||NO|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, including:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our Clients. For example, when Visitors provide information while registering for and using our Service through our Client Sites, and our Clients provide that information to us related to the Service for which they engage us.
- Indirectly from our Clients or their agents through their use of our Service and Visitors use of our Service, including data about Visitors we collect from our Clients through Visitors use of our Service. We also receive information that is collected automatically when Visitors visit Client Sites and use our Service, such as products or services viewed.
- Directly and indirectly from activity on our Website. For example, from your communications submitted through our Website’s portals, billing information you provide to us, or Website usage details collected automatically.
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our Website and our Service and present their contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that Personal Information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
Categories: A, B, D. F and G above.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Our service providers.
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any Personal Information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. Our obligations differ depending on whether we received your Personal Information through our Clients, or we obtained it through our Website.
Personal Information Collected Through Client Sites
When we receive and process Personal Information from our Clients for their business purposes, Ordergroove is a “service provider” to our Clients in respect of Personal Information about Visitors to Client Sites that Clients provide us. Ordergroove has no direct relationship with Visitors to Client Sites, and any such Visitors who seek to access or who seek to correct, amend, or delete their Personal Information should direct their requests to our relevant Client which has transferred such Personal Information to Ordergroove for processing. We will assist our Clients in fulfilling their obligations under the CCPA to respond to such requests by individuals regarding their Personal Information.
Personal Information Collected Through Our Website
If we receive a request from you seeking to exercise your CCPA rights regarding your Personal Information that we collected through our Website, we will comply with your request in a timely manner.
Your Rights Under CCPA
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and verify your request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- Whether we sell that Personal Information (we currently do not), and if so, our business or commercial purpose for selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- (Applicable if we sell or disclose your Personal Information for a business purpose) Two separate lists disclosing:
- Sales, identifying the Personal Information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- 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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
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 also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- 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. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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If, for whatever reason, you have any questions, comments, complaints or compliments about the privacy of our Service or this Website, please contact our email support via the address listed below. Please also use our email address if you believe you have received a marketing communication from Ordergroove that you feel makes use of your Personal Information in an unauthorized or unwelcome way.
Phone: (866) 253-1261
Our support email: firstname.lastname@example.org
Postal Address: 75 Broad Street, 23rd Floor, New York, NY 10004, ATTN: Privacy Officer
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WHAT ARE COOKIES?
A Cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website and Service. The Cookie will collect information relating to your use of our Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at our Website or our Service via a link from third party site, the URL of the linking page.
In addition to Cookies, our Website and email marketing communications may use web beacons. A web beacon, also known as a tracking pixel, is a line of code which is used by a website or email marketing communications. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF.
WHAT ARE THE DIFFERENT TYPES OF COOKIES AND HOW DO WE USE THEM?
Essential – These are Cookies which are essential for the running of our Website and the Service. Without these Cookies, parts of our Website and Service would not function. These Cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.
Examples of how we may use essential Cookies include:
Setting unique identifiers for each unique visitor, so that Website numbers can be analyzed.
Functional – These Cookies are used to remember your preferences on our Website and Service and to provide enhanced, more personal features. The information collected by these Cookies is usually anonymized, so we cannot identify you personally. Functional Cookies do not track your internet usage or gather information which could be used for selling advertising.
Examples of how we may use functional Cookies include:
Gathering data about visits to our Website and Service, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from
Eliminating the need for returning users to re-enter their login details.
Analytical Performance – Analytical performance Cookies are used to monitor the performance of our Website, for example, to determine the number of page views and the number of unique users our Website and Service has. We use this information to improve user experience or identify areas of the Website and Service which may require maintenance. The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.
Examples of how we may use analytical Cookies include:
Measuring users’ behavior
Analyze which pages are viewed and how long for and which links are followed to better develop our Website and Service
Third Party Cookies – You may notice on some pages of our Website and Service that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, Vimeo, these third party service providers may set their own Cookies on your device. We do not control the use of these third party Cookies and cannot access them due to the way that Cookies work, as Cookies can only be accessed by the party who originally set them. Please check the third party websites for more information about these Cookies.
HOW CAN YOU MANAGE OR OPT OUT OF COOKIES?
Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control Cookies. In some cases, you can choose to accept Cookies from the primary site, but block them from third parties. In others, you can block Cookies from specific third parties, or clear out all Cookies. Deleting or blocking Cookies may reduce functionality of the Website and the Service. To learn more about how to reject Cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.
Opting out of Analytical Performance Cookies
We use Google Analytics and Hubspot for Website Analytics Cookies. If you would like to opt out of Google Analytics Cookies, please do so by clicking on the link below:
Google Analytics – https://tools.google.com/dlpage/gaoptout
FURTHER INFORMATION AND CONTACT DETAILS
If you have any questions about or if you would like more information on the Cookies that we use and their purposes, please contact us as set forth in the “Contact Us” section below.