As of January 1, 2023
Table of Contents
- Personal Data Collected
- Use and Disclosure of Personal Data
- Collection and Use of Other Data
- Our Advertising
- Data Integrity; Retention Period
- Choice; Opt-Out
- Correct: Update; Accessibility; Conflicts
- Do Not Track Disclosures
- Data Controller
- Cross Border Transfer of Personal Data
- Contact Us
- European Residents: Your Privacy Rights
- California Residents: Your Privacy Rights
- Virginia, Colorado, Connecticut, and Utah Residents: Your Privacy Rights
Electronic Recyclers International, Inc. (“ERI”, “Company”, “we”, “us”, “our”) is in the business of IT asset disposition and the collecting, handling, transporting, dismantling, and recycling of electronic waste in a safe and socially responsible manner consistent with all applicable laws, rules, and regulations.
ERI cares about the privacy of our users (“users”, “you”, “your”) and takes our privacy obligations seriously. Please read the following to learn more about ERI’s privacy practices.
This Policy covers your access to this Site. Our Site is not directed to and is not intended for access and use by persons under the age of 18. We do not intentionally collect or use Personal Data from users that we have reason to believe are under the age of 18. California Civil Code Section 22581 permits minors under the age of 18 years, or their parents or guardians, to request and obtain removal of their information.
To request removal of your personal information please contact us using the methods described in this Policy. Note that removal under the law does not ensure complete or comprehensive removal of your information.
2. Personal Data Collected
This Policy covers our treatment of personally identifiable information (“Personal Data”) that we may gather while you access the Site or use our Services.
Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, usage data, phone numbers, and unique device identifiers (“Personal Data”). Such information may include, without limitation, the following:
- First and last name
- Company name
- Email address
- Mailing address
- Telephone number
- IP Address
- Account Code (can include email addresses)
- Browser information
- Credit card and credit card CVV (for online purchasing of Services)
- Transaction and Billing Data
We may need to collect and process Personal Data in order to provide requested information or Services to you (including this Site) or because we are legally required to do so.
- Account Registration. We request Personal Data from you if this Site requires registration. The registration process requests that you provide your name, email address, address, phone number, company affiliation, if any, and other similar information. This information must be stored on this Site, and is accessible to anyone with whom you share your username and password. For this reason, please safeguard your username and password carefully and do not disclose it to any other person.
- Voluntary Disclosure. We may collect Personal Data voluntarily provided by you, including in emails to this Site, online forms, order and registration forms, surveys, promotion participation, phone calls and online chats with our customer service staff and through other means.
- Log data. We may collect log data, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.
- Usage information. We may collect usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information), content interactions (including searches, views, downloads, and prints), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction, and similar data.
- Other Means. We may collect information through various other means, including from selected third-party business partners that we may utilize to deliver certain content, products, or services or to enhance your experience.
We ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us.
3. Use and Disclosure of Personal Data
Our primary goal in collecting, using, and sharing your information is to enhance and improve our Services. To that end, we will only use Personal Data for legitimate business purposes, including the following:
- Fulfillment of Requests. We may use Personal Data about you (a) to deliver products and services to you, (b) provide you with information about products and services you’ve ordered, (c) for internal research and development purposes, (d) when it is necessary for employees, agents and contractors to operate or maintain this Site or to correct a technical problem, (e) to detect and prevent fraud and abuse to ensure the security and protection of all customers and others, such as to verify the existence or condition of your account; (f) to comply with the law and our legal obligations, including to respond to a request or order from a court, regulator, or government authority; and (g) to effectuate the sale, merger, acquisition, or other disposition of our assets or business (including in connection with any bankruptcy or similar proceedings). We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Other Communications. From time to time, we may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you. If you or your employer is one of our customers, we may also inform you of such products, programs, services and promotions using Personal Data about you that you or your employer provided to us. If you would prefer that we not send electronic marketing messages to you, please see the “opt-out” section below.
- Promotions. We may operate contests and similar promotions (collectively, “Promotions”). If you choose to enter the Promotions, we typically ask you for certain Personal Data when you enter and, if applicable, win a Promotion. You should carefully review the rules of each Promotion in which you participate, as they may contain additional important information about our use of Personal Data about you. To the extent that the terms and conditions of such rules concerning the treatment of your Personal Data conflict with this Policy, the terms and conditions of such rules shall control. We use this information to operate the Promotions.
- Other Business Purposes. We may also use Personal Data about you for other business purposes, such as data analysis (for example, to improve the efficiency of our Site), editorial and feedback purposes, providing customer support, customizing and improving the content and layout of this Site, completing business transactions (for example, to confirm content requested is received by users), development of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of this Site are of most interest to users), product development, market research, administering individual accounts, and meeting government regulatory requirements such as sales tax collection, audits, etc. We may also use Personal Data of journalist/media contacts for press release distribution or sharing other newsworthy developments related to our business activities. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
We may disclose Personal Data for the following purposes:
- Third-Party Service Providers. We may provide Personal Data to third-party service providers, who provide services to us, including but not limited to, data analysis, order fulfillment, payment processing, and other services.
- Affiliate Communications. We may transfer Personal Data among our affiliates to allow our affiliates to contact you regarding products, programs, services and promotions that they believe may be of interest to you, and such affiliates may otherwise use your Personal Data in accordance with this Policy. If you would prefer not to receive marketing communications from us or our affiliates, please see the “opt-out” section below. We will be the party responsible for jointly-used Personal Data.
- Strategic Partners and Co-Branded Sites. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with us to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”). These special relationships may include co-branded web sites (“co-branded pages”). Any information, including Personal Data that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages will be shared with our third-party partners. You should check these third parties’ web sites for information regarding their privacy practices. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or co-branded pages.
- Conferences and Events. When you attend a conference or event organized by us, your name and contact information may be shared with other attendees.
- Promotions. We may share the Personal Data you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to those Promotions.
- Assignment. We may disclose or transfer any and all Personal Data that we collect to an affiliated entity or a third party (and their respective advisors) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
4. Collection and Use of Other Data
Our service providers and we may also collect and use the following types of data, referred to in this Policy as “Other Data”:
- Monitoring Data. Our service providers and we may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of this Site (“Monitoring Data”). We use Monitoring Data to help us understand who uses this Site and to improve and market it, as well as our other websites and services. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
- Aggregated Data. We may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of this Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also be used for any purpose.
- IP Addresses. When you visit and interact with this Site, we and our third-party service providers may collect Internet Protocol (IP) addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit this Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP addresses to understand how this Site is used by our users, to improve this Site and to enhance user experience of this Site. We may also use your IP address to help diagnose problems with our server and to administer our Site. We may also derive your approximate location from your IP address.
5. Our Advertising
We may use third-party advertising companies to serve advertisements regarding products and Services that may be of interest to you when you access and use this Site, our apps and other websites or online services, based on information relating to your access to and use of this Site and other websites or online services on any of your devices, as well as on information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.
We may store your Personal Data. This information is retained and used in accordance with existing laws, rules, regulations, and other policies.
While there is no such thing as “perfect security” on the Internet, we will take reasonable steps to ensure the safety of your Personal Data. Personal Data is stored on our server and is not publicly accessible. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we take reasonable precautions and have security measures in place to protect the loss, misuse and alteration of the information under our control. Although we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information. We are not responsible for any breach of its security or for the actions of any third parties that may obtain any Personal Data. You are prohibited from violating or attempting to violate security for or otherwise interfering with the operation of this Site. We do not make, and expressly disclaim, any representation or warranty, express or implied, regarding the security or integrity of this Site and your Personal Data.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by sending an email to our General Counsel, Tyler Browning, at firstname.lastname@example.org.
7. Data Integrity; Retention Period
We will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Policy, or authorized by you. We will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you). We depend on you to update or correct your Personal Data whenever necessary.
We will retain Personal Data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
By visiting our Site, you expressly consent to the collection and use by us of Personal Data according to this Policy.
9. Choice; Opt-Out
We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.
- If you no longer want to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by sending an email to our General Counsel, Tyler Browning, at email@example.com.
- If you would prefer that we do not share your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes, you may cease this sharing by sending an email to our General Counsel, Tyler Browning, at firstname.lastname@example.org.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you exercise the second option as described above, we will not be able to remove your Personal Data from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Data (i.e., to which we have already provided your Personal Data as of the date that we implement your request). Further, please note that requesting us not to share your Personal Data with affiliates or unaffiliated third parties may result in you no longer receiving any marketing emails from us. Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages.
You may also indicate your choices regarding marketing-related emails by contacting us via postal mail or telephone using our contact information below.
10. Correct; Update; Accessibility; Conflicts
If you would like to request to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may make a request by contacting us by sending an email to our General Counsel, Tyler Browning, at email@example.com. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
We are committed to ensuring this Policy is accessible to individuals with disabilities. If you wish to access this Policy in an alternative format, please contact us by sending an email to our General Counsel, Tyler Browning, at firstname.lastname@example.org. Depending on the specific interactions you have with us, we may provide different or supplemental privacy statements that describe and govern how we use your personal information. When we do so, those different or supplemental privacy statements apply to those specific interactions you have with us.
Use of this Site is governed by United States law and the laws of the State of California. If you are accessing this Site or Services from a physical location outside of the United States with laws or regulations governing personal data collection, use, and disclosure that are different from United States laws, you agree that by accessing this Site, you are transferring your Personal Data and Other Data to the United States and you consent to the application of the laws of the United States and the State of California with respect to use of this Site and Services and any dispute regarding this Site or this Policy. You further consent to the exclusive jurisdiction of, and agree that venue is proper in, the state and federal courts located in Fresno County, California; provided, however, that if the state and federal courts in Fresno County, California are found not to have exclusive jurisdiction, then you agree to settle all disputes arising out of or relating to this Site or this Policy by binding arbitration in Fresno, California in accordance with the International Arbitration Rules set by the International Centre for Dispute Resolution.
If any provision of this Policy is held by a court of competent jurisdiction to be illegal, unenforceable, or in conflict with any applicable law, the validity of the remaining portions or provisions shall remain in full force and effect.
13. Do Not Track Disclosures
We do not respond to Do Not Track (“DNT”) signals at this time. Some third-party sites may track your actions when you are browsing and accessing content. Various browsers offer a DNT option that sends a signal to third parties that you do not want to be tracked.
14. Data Controller
For the purposes of this Policy, you are the Data Controller of your Personal Data. “Data Controller” means a person who (either alone or jointly or in common with other persons) determined the purposes for which and the manner in which any Personal Data is, or will be, processed. We should be considered only as a processor on your behalf as to any Personal Data that is subject to the requirements of European Union’s Directive 95/46/EC. We may use the services of various third-party service providers in order to process your data more effectively.
15. Cross Border Transfer of Personal Data
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. If you are accessing this Site from outside the United States, you may be sending information, including Personal Data to the United States where our servers are located. That information may be transferred within the United States or back out of the United States to other countries outside your country of residence. These countries do not necessarily have data protection laws as comprehensive as those in your country. Information transferred to the United States or another country is subject to the laws of that country and may be disclosed or accessed in accordance with those laws. By transferring information or allowing information to be transferred to us, you consent to the transfer, processing and storage in countries outside your country of residence. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.
16. Contact Us
If you have any questions about this Policy or the practices of this Site or if you would like to request that we disclose or you wish to exercise any rights granted to you by statute (such as those granted to you by the CCPA, GDPR, ePrivacy Directive, or other applicable statute), please feel free to contact us at:ERI
7815 N. Palm Avenue, Ste. 140
Fresno, California 93711
Attn: General Counsel
TEL: (559) 579-1261
17. European Residents: Your Privacy Rights
18. California Residents: Your Privacy Rights
19. Virginia, Colorado, Connecticut, and Utah Residents: Your Privacy Rights
Sensitive Personal Information
We do not collect personal information that is deemed “sensitive” under the privacy laws of Virginia, Colorado, Connecticut, or Utah.
Sale of Personal Information
We do not sell personal information as that term “sale” is defined in the privacy laws of Virginia, Colorado, Connecticut, or Utah.
We do not use your personal information to provide advertising tailored to your individual interests.
Consumer Privacy Rights
You have certain choices regarding your personal data, as described below.
- Access: You have the right to request that we confirm whether we have your personal data and, if we do, to provide you access to that data. If we processed your data using automated means, you can also request that we provide you a copy of that data in a portable and readily usable format that allows you to transfer it to another company.
- Deletion: You have the right to request that we delete certain personal data we have collected from or about you, subject to certain exceptions under the law. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. In the case of requests submitted online, if we are able to verify your identity (as described below), we may ask you to confirm that you would like your personal data deleted prior to deleting any of your personal data.
- Correction: You have the right to request that we correct inaccuracies in the personal data we have collected about you. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.
- Opt-Out of Sale: You may have the right to opt-out of sale of your personal information. We do not sell personal data as that term “sale” is defined in the privacy laws of Virginia, Colorado, Connecticut, or Utah.
- Opt-Out of Targeted Advertising: You have the right to opt-out of the processing of your personal data for targeted advertising. We do not use personal data for targeted advertising.
How to Submit a Request: If you would like to make a request, please contact General Counsel Tyler Browning at email@example.com.
Consumers in Colorado and Connecticut may authorize another person, acting on the consumer’s behalf, to opt-out of the processing of the consumer’s personal data for targeted advertising or sale. To submit a request as an authorized agent on behalf of a consumer, please send us an email at firstname.lastname@example.org with your first name and a phone number at which we may reach you and indicate in the subject line that you are making an Authorized Agent Request to Opt-Out.
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal data or complying with your request. We may require you to provide information such as: your address, month/day of birth, birth year or similar information.
For Residents of Virginia, Colorado and Connecticut – Appealing Rejected Requests: If your request is rejected, you will receive a notification with the details of reason for rejection and instructions about how to make an appeal. An appeal must be submitted within 15 days of receipt of the rejection notice. We will respond to you within 45 days of your appeal submission.