(a) the Personal Data processing activities of 1WorldSync Holdings, Inc. and its subsidiary, namely 1WorldSync Inc., 300 South Riverside Plaza, Suite 1400, Chicago, IL 60606, United States of America (“1WorldSync”, “we”, “us”, or “our”, if not explicitly referring to one company), which are strictly carried out in a business-to-business context; and
(b) the rights of Data Subjects in this respect (defined below).
Other entities that are covered by this Policy are listed in Annex 1 hereto.
We collect Personal Data that you provide to us through our Sites, through business requests via telephone, fax or email and in connection with other business dealings we may have with you. This includes basic contact information about you, such as your name, title, address, phone number, fax number and email address that you provide to us in this course. It may also include information on the products or services you have shown interest in or purchased from us. Additionally, it may also include information on the company you are working for, which is then treated as Personal Data to the extent associated with your identity. If you use a credit card to purchase a product or service from us, we also may collect information necessary to process the credit card transaction, such as the credit card type, number and expiration date.
Generally, you are not obligated to provide us with your Personal Data. However, if you do not provide this data, we may not be able to make (all the functionalities of) our Sites available to you, answer your questions and/or enter into a contract with you.
Usage Information is automatically collected for each visit of our Sites and stored in our server log files. This information refers to the computer system of the requesting computer. The following information is or may be collected thereby:
When potential customers visit the 1WorldSync Online Store, accessible through some of the Sites, those customers are asked to register with 1WorldSync Inc. by creating a profile or, for repeat customers, updating their customer profile. During registration, 1WorldSync requests company name, mailing address and contact information (which includes name, email and phone number) for the registrant, as well as a technical contact and a billing contact. 1WorldSync will use the technical contact information for communications from 1WorldSync and customer’s trading partners in relation to products and services the customer has requested from 1WorldSync. When a separate billing contact is provided, 1WorldSync will use that billing contact for billing purposes only.
If a customer adds 1WorldSync products or services to its cart in the Online Store, but does not complete the action, it is considered an abandoned cart. 1WorldSync records the following information for each abandoned cart – customer name, company, date of abandoned cart, product name, quantity, cost, email and company’s primary recipient. This information is then relayed to the sales department of 1WorldSync, Inc., where the appropriate sales representative follows up to determine if the customer requires additional assistance to complete the order.
We may receive Personal Data about you from third parties, such as business partners or sales referral partners who recommend or suggest that we contact you for business purposes. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address. It may also include information on the products or services you have shown interest in or may be interested in purchasing from us, as well as information on other companies or individuals with whom you do business. To the extent we have received your consent, we may also obtain Personal Data about you from third parties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction.
We use your Personal Data primarily to facilitate our ongoing and proposed business dealings with you (“Business Use”). This includes to: (1) process business transactions with us that you initiate; (2) establish and maintain customer accounts so that we may provide products or services of ours requested by you or your company; (3) register you as a user of these products or services so that you may access them through our Sites or otherwise; (4) communicate with you about updates, maintenance, outages or other technical matters concerning these products or services; (5) communicate with you about data requests of other participants in our services, with whom you synchronize your data through our products or services; (6) provide you with training regarding usage of these products or services; (7) notify you about changes to any of the policies and procedures for use of these products or services; (8) verify the accuracy of account and technical contact information we have on file for you and your company in relation to these products or services; (9) respond to questions or inquiries that you or your company may have about our products or services, and (10) send you invoices and facilitate payments for our products and services that you have used.
We also may use your Personal Data as required for us to comply with laws and regulations relating to the products or services that we provide in any of the jurisdictions in which we or our affiliated companies operate, including the United States.
We also may use your Personal Data, such as information you provide in connection with complaints or requests, internally within 1WorldSync to help us improve our products or services, or to develop new products or services in order to answer your complaints and comply with your requests. We may also follow up with you to see, if our proposal or solution solved your complaint or request successfully, or otherwise addresses your needs.
If and when you agree, we may use your Personal Data for purposes relating to the marketing of our products and services, or those of our business partners (“Marketing Purposes”). This includes to: (1) send you newsletters, press releases, event announcements and other similar communications regarding the products or services that we offer; (2) market or promote our products or services to you, including by offering you trial or limited access to certain of our products or services; (3) solicit input from you regarding improvement of our products or services; and (4) other purposes that we disclose to you at the time we obtain your consent.
Upon your consent, we may further use your Personal Data to (1) inform you of third-party offerings that we think you or your company may be interested in which relate to our products or services; and (2) send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our products or services.
Your consent can be changed or revoked at any time by clicking the “Unsubscribe” link at the bottom of email communication, or by reaching out to 1WorldSync using the “Contact Us” information below.
From time to time, we may receive Personal Data about you from third parties, such as business partners or sales referral partners, who recommend or suggest that we contact you for business purposes. We receive such Personal Data because you have consented towards the third party that they might share your Personal Data with us. If we use that information based on your consent to contact you, it will only be to see if you are interested in our products or services, or those of our business partners. We will not use this information for other purposes without your consent. In addition, if you inform us that you are not interested in these products or services, we will stop using the information to contact you.
You are responsible for the accuracy of all Personal Data that you provide to us. We will use reasonable efforts to maintain the accuracy and integrity of your Personal Data, and to update that information as appropriate upon your request. We will take reasonable steps to ensure that the Personal Data we collect from you is relevant to its intended use or the purpose of the processing, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorized by you.
We process and retain your Personal Data for the duration of our business relationship. This may not only be for the time necessary to answer any user request, but may also include the initiation of a contract (pre-contractual legal relationship) and the performance of a contract, including any post-contractual obligations.
We share your Personal Data with third parties outside of 1WorldSync only insofar as this is legally permitted or prescribed and we limit the transfer of your Personal Data to what is necessary for the respective purpose. We share your Personal Data with the following categories of recipients: (1) payment service providers and banks, if applicable, during payment processing; (2) external service providers for sending invoices by post or email; (3) logistics service providers; and (4) collection companies and legal advisors in asserting our claims. We may also share your Personal Data with other third parties for purposes disclosed to you and as subsequently authorized by you through your consent. The recipients act independently with your Personal Data, which we have transmitted to them. We will not share your Personal Data with third parties outside of 1WorldSync for their marketing purposes without your consent as required by applicable law.
We may offer various promotions (“Promotions”) through the Sites or elsewhere that may require registration with your Personal Data. If you choose to enter or otherwise participate in a Promotion, your Personal Data may be disclosed to third parties in connection with administration of the Promotion, such as in connection with winner selection, prize fulfillment and as otherwise required by law. By entering into a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. These rules will be displayed to you during the registration process, and you will be asked for your consent to the respective data processing at that time.
1WorldSync or any part of its business, including our Sites, may be sold at some point in the future. Should this occur, your Personal Data may be transferred to a subsequent owner, coowner or operator of the business unit or Site. We also may disclose and transfer your Personal Data in connection with a corporate merger, consolidation, restructuring, the sale of stock or assets, or other corporate change, including, without limitation, during the course of any due diligence process.
In such case, we will enter into an agreement with the third party transferee, which agreement will include the confirmation by such third party that it will provide the same level of protection as what has been contemplated herein and in the EU-US Data Privacy Framework. If such transferee would no longer be able to provide the same level of protection as what has been set out in the EU-US Data Privacy Framework, such party will notify us and the Data Subjects if it makes the determination that it can no longer meet this requirement.
Our Sites and the servers on which they are hosted are operated in various countries around the world in which we conduct our business. Thus, your Personal Data associated with our Sites may be transferred to and/or processed in a country other than that from which it was collected. The data protection laws in those countries may differ from those of the country in which you are located.
In addition to the above circumstances, we may share your Personal Data with other parties as directed by you or subject to your consent. We may also share and otherwise process aggregated information or de-identified information that does not identify you individually with other parties. For example, we may share aggregated statistics about pages viewed on our Sites, demographic information and sales, and other shopping information with third parties to enrich your visitor experience.
Nonetheless, we will impose upon such third-party service providers any and all obligations we are assuming hereunder, and will at least take all measures imposed by mandatory applicable laws in view of protecting and securing the processing of any Personal Data by such third party service providers.
Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including: (a) as necessary to perform a transaction (such as in order to provide the products and services you requested); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to substantiate tax liability); (c) consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies); and (d) necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of our Sites).
If you receive a marketing communication from us by email, you may also opt out of receiving future email marketing communications by following the opt-out instructions provided in that email. Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in. Please note that we reserve the right to send you certain communications relating to transactions you initiate, your customer account, your use of our Sites, or other business matters, and that these communications may be unaffected if you choose to opt-out from marketing communications.
Cookies and similar tracking technologies, such as beacons, scripts, and tags, are small bits of code, usually stored on a user’s computer hard drive or device, which enable a website to “personalize” itself for each user by remembering information about the user’s visit to the website.
You can withdraw your consent to allow for cookies, change your browser settings, and delete the cookies already stored on your computer at any time. Please note that if you delete, or choose not to accept, cookies, you may not be able to utilize all features of the services on our Sites to their fullest potential.
Turning off third-party cookies
You can turn off certain third-party targeting/advertising cookies by visiting the Network Advertising Initiative: https://optout.networkadvertising.org/?c=1 and by visiting Google: https://tools.google.com/dlpage/gaoptout
We also work with third party advertising companies who place their own cookies or similar technology on your browser or device when you visit our Sites and other websites to serve customized advertisements to you as you browse the Internet. As noted above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered. As an additional step, these advertising companies may participate in one of the following self-regulatory programs for online behavioral advertising, with corresponding user opt-outs:
Please note that even if you reject such technology, you may continue to receive advertisements, but the advertisements will not be tailored to your browsing activities and interests.
Marketo. We use Marketo to create landing pages and forms. Marketo allows us to track the activity and form entry of anonymous visitors on our website and landing pages by the use of tracking cookies. This serves the purpose of addressing these visitors adequately. Data collected by Marketo includes an IP address and a user’s affiliation (suspected based on the IP address) to: company, city, state, metropolitan region, country of origin. We have ensured that an IP anonymization is activated and your IP address is therefore processed only anonymized.
In accordance with our routine record keeping and applicable law, we may delete certain records that contain your Personal Data. We are under no obligation to store such information indefinitely, and we disclaim any liability arising out of, or related to, the destruction of that information.
We do not use automated decision making or profiling (an automated analysis of and decision making on the basis of your Personal Data or personal circumstances).
We will take reasonable precautions to protect your Personal Data in our possession from loss, misuse, and unauthorized access, disclosure, alteration or destruction. We will make reasonable efforts to keep your Personal Data reliable for its intended use, accurate, current and complete. As necessary, we will take additional precautions regarding the security of particularly sensitive information, such as credit card information. While we strive to secure your Personal Data, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.
Social Security Protection Policy Statement. It is our policy to protect the confidentiality of Social Security numbers (SSNs) from misuse and improper disclosure by maintaining and enforcing physical, electronic, and procedural safeguards. We prohibit unlawful disclosure of SSNs, and limit access to SSNs to our personnel who need access to SSNs in order to perform their job functions. We do not disclose SSNs to third parties except where required or permitted by law.
The Sites may contain various links to other third-party websites or applications, which may provide additional information, goods, services and/or promotions. These third-party websites are owned and operated independently of 1WorldSync, and may have their own separate privacy and data collection practices. We are not responsible for the privacy practices of any third party. Therefore, you should review their privacy policies and practices prior to interacting with their websites or applications, using any of their tools, or sharing any of your Personal Data with them.
The Sites are intended for business use, and we do not knowingly collect any Personal Data from children younger than the age of eighteen (18), or otherwise as prohibited by applicable law.
Consistent with the “Information We Collect From or About You“ section above, we collect certain categories and specific pieces of information about individuals that are considered “Personal Information” in California. As detailed above, we may collect this Personal Information from you and other third parties. We collect, share and disclose Personal Information for the business and commercial purposes described in the “Purposes for Which We Use Your Information“ and “With Whom We May Share Your Information” sections above.
We do not sell Personal Information, as this term is defined under California law.
Should you wish to request the exercise of your other rights as detailed above with regard to your Personal Information, we will not discriminate against you by offering you different pricing, products or services, or by providing you with a different level or quality of products or services, based solely upon this request. Please see the “Contact us” section below if you have questions or wish to exercise such rights.
If you are a California consumer and you wish to exercise your rights as outlined in this section, you may need to provide information such as name and e-mail so that we can verify your identity. We will use the information you provide when exercising your rights for no other purpose other than to verify your identity. You also have the option of designating an authorized agent to exercise your rights on your behalf. For authorized agents submitting requests on behalf of California residents, please contact us as described below, with any evidence you have that you have been authorized by a California consumer to submit a request on their behalf.
Shine the Light. We do not rent, sell, or share your Personal Information with nonaffiliated companies for their direct marketing purposes, unless we have your permission. You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.
You can exercise any of these rights by contacting us through the methods described in the “Contact Us” section below.
Please note: To protect your privacy, we may ask for additional information to verify your identity in order for us to respond to your request
Users in the EEA and UK only:
Under EU Regulation 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, including the United Kingdom’s substantially similar law as it takes effect in the United Kingdom by virtue of the Data Protection Act 2018 (collectively the “GDPR”), you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country of residence. You can exercise any of these rights by contacting us through our email, phone or mailing address in the “Contact Us” section below.
Former, current, or prospective corporate customer contacts have the right to exercise choice (opt-out) from our use of their GDPR Personal Data for direct marketing purposes. To exercise this right, please follow the instructions in any direct marketing message you may have received (e.g., click the provided opt-out link in the email message or send us an email or postal mail request to opt-out in accordance the instructions provided in the direct marketing message).
Please contact us as specified below if you have any questions. In certain situations, we may be required to disclose GDPR Personal Data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
Please contact us at email@example.com if you have any questions, wish to exercise your rights of access, or seek other assistance as described above.
1WorldSync, Inc. safeguards personal data received in the United States from the United Kingdom (“UK”), European Union, or European Economic Area (“EU”) about former, current, or prospective corporate customer contacts and which is regulated by the (UK) GDPR. We are committed to protecting such GDPR Personal Data in accordance with our obligations under applicable law, such as GDPR Articles 45 to 50, and the Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.
1WorldSync Inc. has implemented appropriate cross-border transfer solutions in accordance with the GDPR, such as European Commission Standard Contractual Clauses (also known as Model Contractual Clauses) and the UK’s International Data Transfer Addendum (UK Addendum) as the legal basis for transferring personal data to third countries, including the United States. To the extent permitted by applicable law, your use of this site constitutes your consent to the transfer of your Personal Data to 1WorldSync Inc. in the United States in the context of the EU-US Data Privacy Framework as set out in Commission Implementing Decision of July 10, 2023 pursuant to the GDPR on the adequate level of protection of personal data under the EU-US Data Privacy Framework.
In all cases where 1WorldSync Inc. transfers personal information to a third party acting as a controller, 1WorldSync Inc. will comply with the Notice and Choice Principles. 1WorldSync Inc. will enter into a contract with the third-party controller that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by you and that the recipient will provide the same level of protection as the Principles and will notify 1WorldSync Inc. if it makes a determination that it can no longer meet this obligation. The contract also provides that when such a determination is made the third party controller will cease processing or takes other reasonable and appropriate steps to remediate.
In all cases where 1WorldSync Inc. transfers personal data to a third party acting as an agent (processor for GDPR purposes), 1WorldSync Inc. will: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles; (iv) require the agent to notify 1WorldSync Inc. if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of 1WorldSync Inc.’s contract with that agent to the U.S. Department of Commerce upon request.
When we transfer your information to third parties we comply with the requirements of the legal protections that cover your information. For example, when we perform an onward transfer of your information protected under the GDPR, we remain responsible for the processing of your personal information. For information subject to an onward transfer by us under the Data Privacy Framework, we will remain liable under the Data Privacy Framework Principles if a recipient of your protected personal information processes such personal information in a manner inconsistent with the Principles, unless we are able to prove that we are not responsible for the event giving rise to the damage.
If you would like to exercise your rights under this Policy or the GDPR, or would like to lodge a complaints with respect to the implementation of this Policy and our processing of your Personal Data, please contact:
1WorldSync, Inc 300 S. Riverside Plaza, Ste. 1400,
Chicago, Illinois, 60606, United States of America
Associate General Counsel
Please note that we may request official identification information, such as a copy of your ID card, drivers’ license, etc. from you when you submit a complaint.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, 1WorldSync Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss- U.S. DPF.
You may, subject to its terms, invoke binding arbitration in accordance with Annex I of the DPF Principles:https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset35584=2
This provides that you may invoke binding arbitration by delivering notice to 1WorldSync Inc. and following the procedures and subject to conditions set forth in Annex I of the Principles.
Please note that we are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
We will verify on a regular basis whether this Policy and our data protection processes and procedures are in line with applicable laws. To this end, we will – as the case may be – perform a self-assessment, engage into an outside compliance review, either directly or with the assistance of one or more third parties.
1WorldSync, Inc. 300 South Riverside Plaza, Suite 1400, Chicago, IL 60606, U.S.A.
Telephone: +1 866 280 4013 within the U.S.
Telephone: +1 937-610-4223 outside the U.S.