Last revised and updated: March 4, 2015
Steelcase Inc., a Michigan corporation, with a registered mailing address at 901 44th Street SE, Grand Rapids, Michigan 49508 USA (“Company“, “we” or “us”), respect your privacy and we are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit www.steelcase.com (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies solely to information we collect on this Website and in e-mail, text and other electronic messages between you and this Website. It does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party (including our affiliates) that may link to or be accessible from or on this Website.
Steelcase complies with the European and international legal framework, and more precisely with the European Directive 95/46/CE, and the U.S.–EU Safe Harbor Framework and the U.S.–Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. To learn more about the Safe Harbor program, and to view Steelcase’s certification, please visit http://www.export.gov/safeharbor/. Information about Steelcase’s participation in Safe Harbor can be found in the section set out below entitled “Safe Harbor Participation.”
Our Website does not knowingly intend to collect personal information from children under 13 years of age. If you are under 13, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.
Information We Collect About You and How We Collect It
We may collect several types of information from and about users of our Website, including information: (a) by which you may be personally identified and that you will provide on a voluntary basis, such as name, postal address, e-mail address, telephone number or any other information that can be used to identify, describe, locate or contact you online or offline should you wish so (“personal information”) to provide you information on our products and services; (b) that is about you but individually does not identify you, such as the contents of your comments and postings on the Website; and/or (c) about your internet connection, the equipment you use to access our Website and usage details to improve your access and visit of our Website.
We collect this information: (a) directly from you when you provide it to us; and/or (b) automatically as you navigate through the site, including usage details, IP addresses and information collected through cookies.
Information You Provide to Us
The information you provide directly to us on or through our Website may include: (a) information provided at the time of registering to use our Website or when requesting further services; (b) records and copies of your correspondence (including e-mail addresses), if you contact us; (c) your responses to surveys that we might ask you to complete for research purposes; (d) your search queries on the Website; and/or (e) details of transactions you carry out through our Website and their fulfillment.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect information about your equipment, browsing actions and patterns, including: (a) details of your visits to our Website and other communication data and the resources that you access and use on the Website; and (b) information about your computer and internet connection, including your IP address, operating system and browser type. Other parties such as third-party advertising partners and analytics providers may collect and use such data to serve tailored ads to your device. For more information about third-party interest-based online/behavioral advertising (and opting out of such use), see “Tracking Technologies and Advertising” set out later in this policy.
The information we collect automatically is statistical data and does not include direct personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to store information about your preferences, allowing us to customize our Website according to your individual interests and recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices about How We Use and Disclose Your Information set out later in this policy.
To comply with current legislation, we need to ask for your consent to set the performance cookies described above. When you arrive on our Website a pop-up message will appear asking for your consent to place cookies on your device. Once your consent has been provided, this message will not appear again when you revisit. If you, or another user of your computer, wish to withdraw your consent at any time, you can do so by altering your browser settings or consulting the menu available in the cookies banner.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information for the following purposes: (a) to present our Website and its contents to you; (b) to provide you with information, products or services that you request from us; (c) to analyze and improve our products and services; and (d) to market Steelcase products and services.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restrictionunder the conditions set forth in this section.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our products or services, you can opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request using the “Contact Us” form [www.steelcase.com/contact-us/]. If we have sent you a promotional e-mail, you may click on the opt-out option included in the email and thus send us a return e-mail asking to be omitted from future e-mail distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
Accessing and Correcting Your Information
You can review and change your personal information by logging into the Website and visiting your account profile page. You may also send us an e-mail using the “Contact Us” form [www.steelcase.com/contact-us/] to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Safe Harbor Participation
We recognize that the European Union (“EU”) has an “omnibus” data protection regime established pursuant to the European Data Protection Directive (95/46/EC) (the “Directive”). The Directive generally restricts the transfer of personally identifiable information about individuals in the EU to the United States, unless there is “adequate protection” for such information when it is received in the United States. To address this restriction and equal restrictions in Switzerland, we adhere to Safe Harbor with respect to personally identifiable information about individual contacts for our customers, dealers and vendors in the EU and Switzerland (“EU and Swiss Personal Information”) for the purposes described below, as well as for our employees in the EU and Switzerland. Employees in the EU and Switzerland are provided with information regarding Steelcase’s employee data privacy practices and Safe Harbor via a separate policy.
Collection, Use, and Disclosure of EU and Swiss Personal Information
Steelcase collects, uses, and discloses EU and Swiss Personal Information in the ordinary course of its business. In particular, Steelcase may obtain in the US the following types of EU and Swiss Personal Information about individual contacts for customers, dealers, and vendors (“EU and Swiss Data Subjects”): name, work contact information (phone, fax, address, and email address); and job title.
Steelcase may disclose EU and Swiss Personal Information to its affiliates, subsidiaries, business partners, and service providers for the purposes listed above. In situations where Steelcase discloses EU and Swiss Personal Information to any third parties acting as service providers or “agents” on behalf of Steelcase, Steelcase will require the recipient to protect the disclosed EU and Swiss Personal Information in accordance with the relevant Safe Harbor Principles, or otherwise take steps to ensure that the EU and Swiss Personal Information is appropriately protected in accordance with their respective data privacy laws. With respect to any sharing of EU and Swiss Personal Information for purposes of marketing Steelcase products and services, Steelcase obtains warranties that its affiliates, subsidiaries, business partners and service providers will use and disclose as relevant such EU and Swiss Personal Information only for the purposes listed above. In certain situations, EU and Swiss Data Subjects may seek to opt-out of disclosures of their EU and Swiss Personal Information or should they wish to know where these data recipient are located, please contact Steelcase at email@example.com.
Data Processor Activities
In certain situations, Steelcase may obtain access to information about its customers’ employees and other end users in the EU and Switzerland for the purpose of providing consulting services about office furniture configuration and other matters for such customers (“EU and Swiss Processor Information”). These customers act as the data controller for any EU and Swiss Processor Information collected in the EU and Switzerland and subsequently transferred to Steelcase in the United States. Steelcase acts as a data processor on behalf of its customers with respect to such EU and Swiss Processor Information and accordingly carries out their instructions with regard to the collection, processing, and protection of EU and Swiss Processor Information.
Data Security, Integrity and Access
Steelcase takes reasonable precautions to protect EU and Swiss Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Steelcase makes reasonable efforts to keep EU and Swiss Personal Information reliable for its intended use, accurate, current and complete. Steelcase also provides EU and Swiss Data Subjects with the opportunity to access, review, delete and correct their own EU and Swiss Personal Information, and otherwise provides such individuals’ access to EU and Swiss Personal Information. Individuals may contact the Steelcase Safe Harbor Privacy Contact identified below to review EU and Swiss Personal Information about them or to object for legitimate purposes. However, for Processor Information such individuals may first wish to contact their own company with questions regarding EU and Swiss Personal Information shared with Steelcase, as that might be the most efficient means of addressing such issues. Steelcase reserves the right to take reasonable steps to authenticate the identity of any such individual seeking access to EU and Swiss Personal Information.
Steelcase may disclose EU and Swiss Personal Information as necessary in connection with the sale or transfer of all or part of its business, where required or permitted by law, where Steelcase believes that such disclosures are appropriate in connection with a law enforcement request or otherwise permitted by Safe Harbor, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud or enforce or apply Steelcase agreements.
Safe Harbor Privacy Contact
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