EM Upholstery Technology & LeatherTeck Privacy Policy
Last Updated: September 5th, 2024
I. Overview
This Privacy Policy describes how EM Upholstery Technology & LeatherTeck (“EM Upholstery Technology & LeatherTeck”) collects, stores, uses, discloses, and secures your personal information when you visit our website and otherwise engage with us, including through email, telephone and our in-person locations (collectively, the “Services”). In this Privacy Policy, the terms “company,” ”us,” “we,” and “our” refer to EM Upholstery Technology & LeatherTeck and its affiliates and subsidiaries, and the terms “you” and “your” means you as the user of the Services.
Please read this Privacy Policy carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access the Services.
II. Your Personal Information and Our Business Model
We market and sell our products in both a wholesale and retail capacity. In our wholesale business, we sell our products to restylers, OEM auto manufacturers, and automotive dealerships. Restylers offer our products directly to you and to new car dealerships. We do not typically receive your personal information when you provide your information to a restyler.
We also offer our products and warranty services directly to you. As part of our direct to consumer offering, the personal information you provide to us — including warranty information on products you purchase from a restyler or auto dealership that you register directly with us — is handled in accordance with this Privacy Policy.
III. What We Collect and How We Use and Disclose It
As further described below, when you use or access the Services, and depending on how you interact with us, we collect certain information about you that identifies, describes, or is reasonably capable of being associated with you (“personal information”). We collect, use, and disclose certain types of personal information for various reasons depending on how you interact with us. This section details the types of personal information we collect, how we collect it, the purposes for which we collect your personal information, and how we disclose your personal information.
Personal Information You Provide to Us
When you use or access the Services, we may collect certain personal information, including:
- Your name, email, phone number, address, warranty information, vehicle information, and any other such related information you provide us;
- Commercial information, such as the products or services you purchased or considered;
- Your financial information including your payment or billing information;
- Applicant information such as information included in your resume or CV, references, education history, and job history;
- Any other information you choose to provide such as information you provide when acting as an employee or representative of a business we engage with, or information you provide when you communicate with us, for example, by engaging with us on social media or sending us a message through the Services.
Information We Collect Automatically
We also collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use third party cookies, tags, pixels, and similar tracking technologies (“Cookies”). Usage Data includes:
- The date and time you accessed the Services;
- Your Internet Protocol (IP) address, or the proxy address of your Internet Service Provider;
- The name and IP address of the company server that received and logged the request;
- The web pages, and other resources you accessed on the Services;
- The name and version of your web browser;
- Device type, operating system, and unique identifier;
- Approximate location;
- Clickstream data and ad impressions;
- The content of any sent or received Cookie;
- The website that you visited before accessing our Services;
- Other status codes and values associated with your browsing session.
We use Usage Data to provide, customize, advertise, evaluate, improve, and secure our Services, including to operate our website, analyze performance and analytics, and deliver advertisements. For more information on how we use Cookies and your choices, see the section below, Cookies and Other Tracking Technologies.
Information Collected From Other Sources
We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes:
- Analytics data we receive from analytics providers such as Google Analytics;
- Information we receive from career websites, such as LinkedIn, Monster, or Indeed;
- Information we receive from consumer marketing databases or other data enrichment companies.
How We Use Your Personal Information
We use your personal information to:
- Provide you with the Services, including services or products you request and complete transactions;
- Communicate with you, including to provide you with customer support, updates on our products and offerings and other information that may be of interest to you;
- Register products you purchased from a restyler or auto dealership;
- Maintain our business relationship, including by enhancing the safety and security of our Services (e.g., troubleshooting, data analysis, testing, system maintenance, and reporting);
- Gather insights about your experience to evaluate and improve our offerings and conduct internal research and development;
- Process your application for employment and evaluate your candidacy;
- Engage with a business that you are an employee of or otherwise represent;
- Enforce any applicable terms of service, comply with any legal obligations and protect the Services, our rights, and the rights of employees, users, or other individuals.
Finally, we may deidentify your information such that it cannot reasonably be linked to you and use such deidentified information in accordance with applicable law. To the extent we process any deidentified information, we will maintain and use such information in deidentified form and not attempt to re-identify the information, except as permitted by law.
With Whom We May Disclose Your Personal Information
EM Upholstery Technology & LeatherTeck does not share any personal information, including SMS opt-in consent, with any third-party organizations except for legitimate purpose subject to this Privacy Policy, including:
- When you direct us to disclose your information with our installer and restyler partners for sales and marketing purposes;
- With vendors or other service providers, contractors, and agents who perform services on our behalf, like payment processing, data analysis, email and hosting services, and customer services and support. Vendors, service providers, contractors, and agents may access your personal information after they agree to use it solely as we direct to provide the requested service;
- With third parties for advertising and marketing purposes, such as business partners and other websites and platforms that drive traffic to our website;
- Third parties to whom you request or direct us to disclose your information, or otherwise with your permission or consent;
- Third parties in connection with or anticipation of an asset sale, merger, or other business transaction, including in the context of a bankruptcy.
We may also disclose your information as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.
IV. Cookies and Other Tracking Technologies
Cookies. Our Services use cookies, tags, pixels, and similar tracking technologies (“Cookies”).
A Cookie is a small piece of text that is placed on your website browser when you visit a website. These include our own first-party Cookies as well as third-party Cookies of our service providers and marketing partners. Some Cookies are only stored temporarily and destroyed each time you close your web browser. Our website also uses persistent Cookies, which do not delete when you close your browser and may collect and store data for a set period of time after you’ve left our website. You can find out more about Cookies in general and how they work at Cookiepedia.
How We Use Cookies. We use Cookies for the following purposes:
- Website Operation. Cookies help us run our Services securely and enable basic functions like page navigation.
- Performance and Analytics. Cookies help us analyze how you interact with our Services. This enables us to monitor and improve our website performance, services, and your experience.
- Advertisements. Cookies allow us to deliver advertisements that are tailored to your interests. Our third party advertising partners may use the Cookies to build a profile of your interests, deliver relevant advertising on other sites, and measure the efficiency of the advertisements.
How to Manage Cookies. If you wish to prevent Cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain Cookies or notify you when a Cookie is set. If you block Cookies, or Google Analytics tracking, certain features on our website may not work. For more information on how you can customize your browser’s Cookie setting please visit the link to your web browser below:
For more information on how you can opt-out of Google Analytics tracking, please visit the link: Google Analytics Optout.
Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. Our website recognizes the Global Privacy Control (GPC) signal, which enables you to opt-out of certain uses or disclosures of your information. If you notify us of your preference through GPC, we will honor your request only for the browser or device that sends the GPC signal. To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/.
You may opt-out of interest-based advertising from certain advertising providers by visiting the Digital Advertising Alliance’s or Network Advertising Initiative’s websites. We are not responsible for the completeness, effectiveness, or accuracy of any third party opt-out options or programs.
V. Information Regarding Individuals Under the Age of 16
Our website is intended for users who are 16 years or older and we do not knowingly collect information from users under 16 years old. If we become aware that we have collected information from a user under 16 years old, we will delete such information from our records. We have no actual knowledge that we disclose or sell information of users under 16 years of age. If you are a parent or legal guardian and believe your child has given us information and you did not provide consent, please call us at 760-980-2383 or email us at [email protected] for assistance.
VI. California Residents
This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information” as these terms are defined under the California Consumer Privacy Act. If you are not a California resident, this section does not apply to you.
In the preceding 12 months, we collected and disclosed the following categories of personal information and sensitive personal information (denoted by *) about residents:
| Category | Categories of Recipients |
|---|---|
| Identifiers such as name, e-mail address, address, phone number, and IP address | Vendors or other service providers Third parties for advertising and marketing purposes |
| Personal information categories listed in the California Customer Records statute such as [name, Social Security number*, address, and telephone number] | Vendors or other service providers |
| Characteristics of protected classifications under California or federal law such as [race*, color*, religion* or creed*, national origin or ancestry*, sex (including gender, pregnancy, sexual orientation*, and gender identity*), age, physical or mental disability*, veteran status, genetic information*, and citizenship] | Vendors or other service providers |
| Commercial information such as records of products or services purchased or considered | Vendors or other service providers Third parties for advertising and marketing purposes |
| Internet or other similar network activity such as information regarding your interaction with the Services | Vendors or other service providers Third parties for advertising and marketing purposes |
| Geolocation data such as IP address | Vendors or other service providers Third parties for advertising and marketing purposes |
| Professional or employment-related information such as title of profession, employer, professional background | Vendors or other service providers |
| Government Identifiers* such as driver’s license, state identification card, or passport number | Vendors or other service providers |
The specific business or commercial purposes for which we collect your personal information and the categories of sources from which we collect your personal information are described in the section above, What We Collect and How We Use It. We only use and disclose sensitive personal information for the purposes specified in the CCPA. The criteria we use to determine how long to retain your personal information is described in the Data Security and Retention section below.
We do not have actual knowledge that we “sell” or “share” (as those terms are defined under the CCPA and used throughout this section) personal information of residents under 16 years of age. However, we do share certain categories of personal information and, in the preceding 12 months, we have shared the following categories of personal information with third parties for advertising and marketing purposes about residents. For purposes of the CCPA, this may also qualify as a sale of personal information.
| Category |
|---|
| Identifiers such as e-mail address, IP address |
| Commercial information such as records of products or services purchased |
| Internet or other similar network activity such as information regarding your interaction with the Services |
| Geolocation data such as IP address |
| Inferences drawn from other personal information such as a profile reflecting your preferences |
VII. Your Privacy Rights
Depending on where you live, you may have some or all of the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law, including in the event you reside in a state that does not currently grant you these rights.
The Right To Know/Access. You may have the right to request access to your personal information, or for more information about how we process your personal information, including:
- The categories of personal information we collected about you;
- The categories of sources from which we collected that information;
- Our business or commercial purpose for collecting or sharing that information;
- The categories of third parties with whom we disclosed that information; and/or
- The specific pieces of personal information we collected about you.
The Right to Request Deletion. Under certain conditions, you may have the right to request that we delete your personal information. Please note that simply leaving the Services does not delete the personal information we may have collected about you.
The Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
The Right to Opt-Out of Targeted Advertising. You may have a right to opt-out of the processing of your information for the purposes of targeted advertising. See the section above, Cookies and Other Tracking Technologies, for further information.
Right to Opt-Out of Selling or Sharing. You may have a right to direct us not to share your personal information to third parties for advertising and marketing purposes. To exercise this right, please use the following form: Do Not Sell or Share My Personal Information. For information on how we process opt-out preference signals, see the section above, Cookies and Other Tracking Technologies.
How To Exercise These Rights. To submit a request to exercise these rights you may contact us by calling 760-980-2383 or emailing us at [email protected].
Please clearly state that you would like to exercise your privacy rights and briefly describe your request.
If you make a request, we will acknowledge we have received it within ten (10) days. If you do not receive a response, please ensure your request was submitted properly or contact us.
Verification. Before we can respond to your request, we must verify your identity. To verify your identity we may collect information such as your full name, current address, telephone number, and email address. If we are unable to verify your request, we may contact you for more information. If we are still unable to verify your identify after a good faith attempt, we may deny the request and, if so, we will explain the basis for the denial.
Designating an Authorized Agent. You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, you must provide us with proof you have given permission to allow your Authorized Agent to act on your behalf.
Appeal. You may have the right to appeal our decision regarding a request related to these rights by contacting us.
VIII. How We Secure and Retain Your Information
To the extent permitted by applicable law, EM Upholstery Technology & LeatherTeck will retain your personal information only for as long as the company believes it is necessary to fulfill the purposes for which it was collected. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, protect ourselves, including our rights, property or products or for the purpose of meeting any legal, accounting, or other reporting requirements or obligations.
Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.
IX. Legal Disclaimer
Nothing in this Notice restricts EM Upholstery Technology & LeatherTeck’s ability to:
- Comply with federal, state, or local laws;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
- Exercise or defend legal claims.
X. Changes to This Policy
We may modify this Privacy Policy from time to time, in which case we will update the “Last Revised” date. We will not retroactively use or disclose data in a manner that is materially different from this Privacy Policy without first making commercially reasonable efforts to provide you notice and take additional steps required by applicable law. This Privacy Policy is reviewed annually and we will use commercially reasonable means to inform you of any changes. If you do not agree to any updates to this Privacy Policy, please do not continue to use or access the Services.
XI. Questions
If you have questions or concerns regarding this Privacy Policy or the handling of your personal information, please call us at 760-980-2383 or email [email protected].
Effective Date: September 5, 2024
