Privacy Notice

Empire Distributors, Inc.
Website Privacy Notice
 
 
Effective Date: January 13, 2020

1.     What is this document and why should you read it?
This Privacy Notice applies to anyone who visits our website, including Empire customers, employees, individuals who wish to review job opportunities that are available through Empire, and Empire suppliers and vendors and their representatives.  It sets out the basis upon which we collect, use, store, share and keep secure any personal information you provide to us when you visit this website.   It also describes how we use the information you provide to us through this website.

Finally, this Privacy Notice sets out details on how to contact us if you have any questions or comments.

2.     What types of personal information do we collect and where do we get it from?
For ALL visitors to this website (including but not limited to Empire customers, suppliers, employees, and applicants), we collect any information about you that you submit through this website. For example, if you use the “contact us” feature of the website, we will collect your name and contact information, as well as any message that you submit.

If you are an Empire supplier, you may access your supplier account via the supplier portal that is included as part of this website.  You will be required to submit your unique supplier username and password in order to access the supplier portal.  However, no additional personal information required by Empire to administer your supplier account will be solicited by Empire through this website, nor will any personal information related to you as a supplier be stored/maintained on this website.

If you wish to apply for a job that is advertised through this website, you will be directed to a separate third-party website where you will complete and submit your application for employment.  As part of that application, you will be asked to provide your name, contact information, employment history, and any other information needed to process your job application. None of your personal applicant information is solicited by Empire through this website, nor will your personal applicant information be maintained/stored by Empire on this website.

If you are an Empire employee and you utilize this website to access the Empire employee portal, you will be required to submit your unique Empire username and password in order to access the employee portal.  No additional personal information required by Empire to administer our employment relationship with you will be solicited by Empire through this website, nor will your personal employment information be maintained/stored by Empire on this website.

As described in more detail below, we also may collect some information about you through our use of cookies.

3.     Why do we process personal information about you?
We will typically collect your personal information directly from you when you call us or send us an email, or through your interaction with our website.

The data we collect from you via this website is necessary in order to perform a number of functions, including to detect security incidents; protect against malicious, deceptive, fraudulent or illegal activity; for compliance management; data analytics; and technological development of our systems.

The personal information about you that we collect via this website includes information within the below categories of data. These categories also represent the categories of personal information that we have collected via this website over the past 12 months. Note that the categories listed below are defined by California state law.  Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect some information within that category.  It does not necessarily mean that we collect all information listed in a particular category for all of our customers.

Category
Source
Purpose of Collection
Disclosed for a Business Purpose?
Who Shared With?
Personal Identifiers.Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
A subset of this information is collected directly from you if you request that we contact you.
A subset of this data is necessary for us to call you or send you email.
No
None

Information About You.Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your 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.
A subset of this information is collected directly from you  if you request that we contact you.

A subset of this data is necessary for us to call you or send you email.

No
None

Usage Information.Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
Cookies and/or web beacons may be used to automatically collect a subset of this information from you when you visit this website.
A subset of this data is used for marketing purposes, including offering you products/services that may be of interest to you.

It is also processed in order to help detect security incidents; protect against malicious, deceptive, fraudulent or illegal activity; for compliance management; data analytics; and technological development of our systems.

Yes
Service providers

Category
Source of Information
Purpose of Collection
Disclosed for a business purpose?
Who Shared With?
Recordings.

Audio, electronic, visual, thermal, olfactory, or similar information.
This information is collected directly from you.
When you call into our call center, or when we call you, we may record the call in order to ensure the quality of our customer support operations.
No
None

4.     Who do we share personal information about you with, and why?
We may share or transfer aggregated personal information that we collect via this website to search engine optimization consultants engaged by Empire to assist us in making this website more accessible and attractive to users.

From time to time, we may also be required to provide your personal information to other persons, such as in the event that we sell any business or assets (in which case we may disclose your personal information to the prospective buyer of such business or assets) or if we, or substantially all of our assets, are acquired by a third party (in which case personal information held by us about you will be one of the transferred assets) or if we are required to disclose your personal information in connection with any legal proceedings or requirements (such as to our lawyers, government agencies, courts or tribunals).

5.     Cookies
When you visit our website(s), we use so-called “cookies” to make our website(s) more user-friendly, effective, and secure. A cookie is a small piece of data sent from a website and stored in a file on your browser. A cookie is useful for having the browser remember specific information across several pages or between visits to a website. In addition to cookies, we use scripting, which is code run on the website to collect information such as actions you have completed on our website or items you click on. We also use “pixels,” which are transparent image files sent from the website to your browser to help us record items like IP address and time. For the purposes of this Policy, we refer to all these technologies as “cookies.”

Our website(s) does not read any information stored in cookies given to you from other websites, except in rare cases where the other website is a provider of information or functionality within our website and that cookie is necessary to make our website function correctly.

Most of the cookies we use are “session cookies” which are automatically deleted as soon as you leave the site. Other cookies, so-called “persistent cookies,” remain on your computer until you delete them. Using these cookies allow us to enhance your experience in interacting with our website, such as by helping recognize your browser the next time you visit and loading previously viewed pages faster. We use cookies to offer you the best possible experience on our website.

We also use cookies to collect browsing information in order to improve your overall experience. We use this information to track website usage and compile statistics. This helps us improve the website, so you will find it more useful and informative, and enable customized promotions that may be of interest to you. We may use the combination of data we collect, such as browsing information and email address, to join known devices together and provide you personalized experiences on the device you are currently using. Impression data from cookies, which indicates who has seen advertisements about our products and services on our website or third party websites, may be used to improve our marketing practices. If you are a current customer, have logged into your account, or provide your email address, we may use analytics software to link data we collect, such as use of our website, opening emails we send you or contacting our customer service center via phone, back to you.

You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. Browsers may also be set up to display a warning when a cookie is used. You may even disable your browser from accepting cookies. Disabling cookies is unique to each browser and device you use. Disabling cookies on one device will restrict the ability to tie that device to other devices you use. Parts of our website may not function properly if you disable cookies. To provide you with the best possible experience while visiting our website, please enable cookies within your browser.

Do Not Track
We do not currently support the capability to respond to web browser “do not track” signals.

Google Analytics
We use a tool called “Google Analytics” to collect information about use of our website. This tool uses persistent cookies to allow us to see behavior information relating to visitor age, gender and interests. We may also use this data to create remarketing lists. Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using Google’s Ad Settings.

You can opt out of Google Analytics without affecting how you visit our website. For more information on opting out of Google Analytics tracking, visit this Google page.

6.     Where do we keep personal information about you and how long do we keep it for?
We store personal information about you in physical files or on computer systems operated by or under the instruction of Empire and/or at our facilities. We will maintain personal information about you for as long as necessary in connection with both our and your legal rights and obligations, and in accordance with our Records Retention Schedule.  We will delete personal information about you in accordance with our Records Retention Schedule.

7.     How do we keep personal information about you secure?
We have reasonable measures in place to prevent personal information from being accidentally lost, used, or accessed in an unauthorized way. We limit access to personal information to those who have a business need for such access. Those individuals who process personal information on our behalf may do so only in an authorized manner. They are also subject to a duty of confidentiality. We have policies in place that regulate how employees within Empire must handle data, including personal information. We limit access to our premises and to our computer networks, and we take reasonable steps to safeguard against unauthorized access to such premises and networks. We have procedures in place to manage any suspected data security breach and will notify you and any applicable regulator of a suspected data security breach consistent with legal requirements.

8.     What are your rights in relation to personal information about you and how can you exercise them?
Depending on where you live, your current jurisdiction and applicable data protection laws, and subject to any relevant restrictions/exemption, you may be entitled to the rights described below regarding your personal information, subject to certain conditions and limitations. If you are a representative of a commercial entity, you may be entitled to these rights effective January 1, 2021.

You may not have access to all of these rights depending on your state of residence, and only those relevant in your jurisdiction will apply. We may, however, choose to offer these rights, even if we are not required to under applicable law.
·       Right to Know – You may be entitled to request that we disclose to you personal information we have collected about you, the categories of sources from which we collected the information, the purposes of collecting the information, the categories of third parties with whom we have shared the information, the categories of personal information that we have shared with third parties for a business purpose, the categories of information sold, and the categories of third parties information is sold to. In some instances, you may have the right to receive the information about you in a portable and readily usable format. Before providing any of this information, we must be able to verify your identity.
·       Right to Opt-Out – You may have the right to opt-out of information sharing that constitutes a “sale” of personal information under California law. However, please be advised that Empire does not share your personal information in a manner that constitutes a “sale” under California law at this time.
·       Right to Deletion – Subject to certain conditions, you may be entitled to request that we delete personal information about you. Before deleting information, we must be able to verify your identity. We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to provide you with certain products and services or where we are legally required to retain certain information.

If you chose to exercise any of these rights, to the extent that they apply, state law prohibits us from discriminating against you on the basis of you choosing to exercise your privacy rights.

Please note that under California law, we are only obligated to respond to personal information requests from the same consumer up to two times in a 12-month period.  In addition, under California law, and for the protection of your personal information, we may be limited in what personal information we can disclose.

You can submit requests to exercise these rights by calling us at 404-572-4100 to speak to a member of our team.

Before providing information you request in accordance with these rights, we must be able to verify your identity. In order to verify your identity, you will need to submit information about yourself, including your name, residency information, contact information and, to the extent applicable, providing your account login credentials.  We will match this information against information we have previously collected about you or provided to you to verify your identity and your request (for example, we may send a verification code to your email or cell phone number on file). If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. We are not obligated to collect additional information in order to enable you to verify your identity. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want personal information about you deleted.

If you would like to appoint an authorized agent to make a request on your behalf, you must provide the agent with written, signed permission to submit privacy right requests on your behalf, or provide a letter from your attorney. The agent or attorney must provide this authorization at the time of request.  Note that we may require you to verify your identity with us directly before we provide any requested information to your approved agent.
Information collected for purposes of verifying your request will only be used for verification.

9.     Where can you find out more?
If you have any questions, concerns, complaints or suggestions regarding our Notice, have any requests related to your personal data pursuant to applicable laws, or otherwise need to contact us, you may do so by calling 404-572-4100.

10.  Children and minors
We do not knowingly collect personal information directly from individuals under 17 years of age.  Our services are not intended for individuals under 17 years of age. No one under 17 years of age should submit or post personal information through our services. We may collect personal information regarding individuals under 17 years of age from their parents or legal guardians, but only as necessary to provide our products and services. We do not knowingly sell the personal information of minors under 17 years of age.

11.  Changes to this Privacy Notice
We may change this Policy at any time, and in accordance with applicable law. We will post the revised policy to our website. The date this Notice was last revised will appear at the top of the page.