Introduction: What Is STANNP and Why Do We Collect Your Information
Stannp, Ltd. (“STANNP”) is a direct mail provider that allows customers to use a SaaS (software as a solution) product to send direct mail. This gives customers a fully digital, integrated solution to their direct mail needs. We collect personal information in order to provide direct mail services for our customers.
This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
B. What Information Does STANNP Collect?
Personal Information Provided to Us
STANNP's customers provide information so that we may provide the Services. This information includes names and contact information (including home address, work address, email address, and phone number).
Personal Information You Provide to Us
At times when you interact with the Services, you may provide Personal Information to STANNP. This information may include: your name, contact information (including home address, work address, email address, and phone number), account credentials (including user name and password), and credit card information.
You may communicate with STANNP through email, mail, in person communications, phone, text, chat, or any other paper and electronic form. When you do so, we may collect your name, contact information (including phone number, email address, work and/or home address), the content of any communication, the metadata associated with any communication, and other such Personal Information. Phone calls may be monitored or recorded.
If you apply for employment, STANNP may collect or you may choose to provide the following: name, contact information (including phone number, email address, work and/or home address), date of birth, demographic information (like gender, age, household income, nationality, and race and ethnicity), immigration status and documentation, schooling and education information, disability information, recommendations, employment information and history, information from interviews, user name or e-mail address, any other information you may provide to STANNP, and other such Personal Information.
You can choose not to provide STANNP with Personal Information. However, doing so will affect our ability to communicate with, provide Services to, employ, or otherwise interact with you.
Personal Information Processed Automatically
When accessing or using STANNP's Websites, Portals, and applications, certain information may be passively collected using various technologies, such as IP addresses and cookies.
An IP address is a number assigned to a computer by an Internet service provider to access the Internet. In most consumer cases, an IP address is dynamic (changing each time connect to the Internet), not static (unique to a particular user's computer).
Personal Information from Third Parties
When STANNP sends mail, we may receive from the United States Postal Service (i) confirmation that the address associated with an individual is a valid address and the mailing has been delivered, or (ii) notice that the address is incorrect or otherwise invalid and the mailing has not been delivered.
Special Categories of Personal Information
Personal Information STANNP Has Collected in the Last 12 Months
C. What Does STANNP Do With Personal Information?
Use of Personal Information
STANNP uses all categories of Personal Information listed above for any and all legal and legitimate businesses purposes, including the following: (a) communicate with individuals; (b) conduct STANNP's business operations, including performing research among individuals who interact with or may interact with the Services; (c) provide the Services; (d) operate, maintain, and improve the Websites, the Portals, and other software and applications; (e) evaluate and hire potential employees; (f) prepare and manage events; (g) investigate and resolve disputes and other issues; (h) disclose to third parties as set forth in this Section and Section D; and (i) any other lawful and legitimate business purpose.
Storage of Personal Information
D. Will STANNP Disclose Personal Information?
STANNP discloses to customers confirmation and notices we receive from the United States Postal Service regarding the delivery of mailings and the validity of individuals' mailing addresses.
Third Party Service Providers
STANNP discloses Personal Information to third parties necessary or appropriate to provide the Services, including printing services, packaging services, delivery services, and any other third party that an individual requests or authorizes STANNP to disclose Personal Information about them to or that is necessary or appropriate for STANNP to disclose Personal Information to in order to provide the Services.
STANNP may sell its assets. In these types of transactions, Personal Information is one of the assets transferred. If STANNP sells all or substantially all of its assets, or if STANNP goes out of business, enters bankruptcy, or goes through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.
Legal Obligations, Protection of STANNP, and Protection of Others
Except as set forth above, we will obtain your consent before disclosing your Personal Information to a third party.
Personal Information STANNP Has Sold to Customers in the Last 12 Months
Personal Information STANNP Has Disclosed to Third Parties in the Last 12 Months
E. What Are STANNP's Legal Bases for Collecting and Using Personal Information?
To the extent that you give STANNP Personal Information about another individual, you will ensure, and hereby represent to STANNP, that each such other individual has consented to STANNP's collection and use of Personal Information about that individual, if and to the extent Privacy Laws require such consent.
F. How Long Will STANNP Retain Personal Information?
Except upon the request of an individual, as explained in Section G below, and except as the Privacy Laws or other legal requirements permit or require otherwise, STANNNP retains Personal Information it uses to provide the Services to a customer until 12 months after the customer stops using the Services.
G. What Are Individuals' Rights With Respect to Personal Information About Them?
Except where permitted or required by Privacy Laws, you have the following rights regarding STANNP's collection and use of your Personal Information.
1. Requests to STANNP
You may request the following from STANNP with respect to your Personal Information:
The correction, updating, deletion, or restriction of collection and use of your Personal Information;
The categories of Personal Information STANNP has collected about you;
The categories of sources from which STANNP has collected your Personal Information;
The envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period;
The business or commercial purpose(s) for collecting and disclosing your Personal Information;
An account of how STANNP has used or is using your Personal Information;
A copy of your Personal Information retained by STANNP, to be delivered in a structured, commonly used and machine readable format to review or to transfer or transmit to another entity without hindrance, to the extent that that is technically feasible;
The categories of third parties with whom STANNP shares your Personal Information;
The categories of your Personal Information that we have shared with third parties, including customers, and the categories of third parties to which we have shared each particular category of Personal Information;
A list of all third parties that have received your Personal Information from STANNP; and
The specific pieces of Personal Information STANNP has collected about you.
If you request that your Personal Information be erased or deleted or that STANNP otherwise restrict its collection and use of Personal Information, STANNP may terminate or limit your access to the Websites, Portals, other applications, and the Services. If STANNP has not collected or used your Personal Information, or has not disclosed your Personal Information to another party, STANNP will inform you of that in response to any of the above requests. Some information may remain in STANNP's backup media after erasure or deletion for a period of time. When you request that STANNP update information, STANNP may retain a copy of the unrevised information in STANNP's records. STANNP also may use any anonymized aggregated statistical data derived from or incorporating Personal Information after it is updated, erased, or deleted, but not in a manner that would identify you.
We will confirm receipt of all such requests and provide information about how STANNP will process the request within 10 days of receipt. We will substantively respond to all such requests within 30 days, subject to lawful extension of that period, and there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. Our verification process varies based on the source and nature of the request, but may include: comparing data in the request against Personal Information we retain; contacting you using other contact information; requesting further information, although we will avoid doing so to the extent possible; and the consideration of certain factors, including the type, sensitivity, and value of your Personal Information, the risk of harm to you posed by an unauthorized request, the likelihood that fraudulent or malicious actors would seek your Personal Information, the manner in which we interact with you, the available technology, and whether the information you have provided to verify your identity is sufficiently robust to protect against fraudulent requests. To the extent permitted by the Privacy Laws, STANNP retains the right to deny any request if we cannot verify that it originated from you.
STANNP retains records of all of the above requests and our responses for 24 months, unless otherwise prohibited by the Privacy Laws.
You may make any of the foregoing requests by contacting STANNP at the contact information in Section P below.
2. Authorized Agent
You may authorize an agent to take any of the acts permitted in this Section G on your behalf. To do so, you must provide written and signed authority to the agent, and written and signed notice to STANNP that STANNP may act on such requests by that agent. You may withdraw such authorization at any time by contacting STANNP at the contact information in Section P below.
3. Withdrawal of Consent
To the extent STANNP collects and uses your Personal Information pursuant to your consent, you may withdraw your consent at any time by contacting STANNP at the contact information in Section P below, although such withdrawal does not affect the lawfulness of Company's use of your Personal Information before such withdrawal. Withdrawal of consent may affect the functionality of the Websites, the Portals, other applications, and the Services.
4. Do Not Sell My Information
Other than providing Personal Information to our customers as described in Section D(1) above, STANNP does not “sell” Personal Information, as that terms is defined in the CCPA. You may opt out of STANNP's disclosure of your Personal Information to our customers by completing the form at the following link: insert link.
You may also opt out of the disclosure of your Personal Information by contacting STANNP at the contact information in Section P below.
We will act upon any request to opt out of all such disclosures of your Personal Information within 15 days of receiving your request. If we have disclosed your Personal Information to any customers after you have submitted your request but before STANNP has complied with that request, we shall notify those customers that you have exercised your right to opt-out and shall direct those customers not to use your Personal Information. STANNP will not contact you about opting in to disclosing your Personal Information for at least 12 months following receipt of the request. Your authorized agent may opt out of the disclosure of your Personal Information to our customers pursuant to the terms of Section G(2) above.
Instructing STANNP to not disclose your Personal Information to our customers will impact STANNP's ability to provide the Services to you.
4. Object or Challenge
You may object to, or otherwise challenge, STANNP's collection and use of your Personal Information. You may do either by contacting STANNP using the contact information in Section P below or by completing the form at the following link: insert link.
STANNP will respond within 30 days. Where such objection is received from an individual whose Personal Information STANNP collects and uses as the processor for a controller (as those terms are defined in the GDPR), STANNP will inform the controller of the objection within 30 days.
5. Filing a Complaint
Regulatory authorities that oversee the Privacy Laws typically advise individuals to file an objection or challenge with the company before lodging a formal complaint with a regulatory authority. If an individual is dissatisfied with STANNP's response to an objection or challenge filed under Section G(4), or wishes to file a complaint with a regulatory authority first, the individual may do so, including as follows:
GDPR: a supervisory authority in the relevant European Union member state;
CCPA: California Attorney General; and
PII Laws: the relevant states' Attorney General's office.
6. Prohibit Automated Processing
At your request, STANNP will terminate any automated decision making, including profiling, that is the sole source of decisions that produce a legal effect concerning or similarly significantly affecting you. Consistent with Section M, STANNP does not use any such automated decision making or profiling at this time.
7. Accessibility for Users with Disabilities
STANNP will not discriminate against you because you have exercised any of the rights above or any other rights you retain pursuant to the Privacy Laws, including, but not limited to by:
Denying goods or services to you;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing a different level or quality of goods or services to you; and
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Consistent with the Privacy Laws, STANNP: (i) retains the right to charge you a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to STANNP by your Personal Information; (ii) may offer financial incentives, including payments to you as compensation, for the collection, disclosure, or deletion of your Personal Information; (iii) may enter you into a financial incentive program only if STANNP clearly describes the material terms of the financial incentive program, so long as you give STANNP prior opt-in consent, which you may revoke at any time; and (iv) shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
H. What Are STANNP's Financial Incentives?
STANNP does not offer any financial incentives for providing Personal Information.
I. Is Personal Information Secure?
STANNP employs reasonable and appropriate technological, physical, and administrative measures to safeguard the confidentiality, integrity, and availability of Personal Information. Individuals seeking additional information about such safeguards may contact STANNP using the contact information in Section P below.
The Websites, the Portals, and other applications may contain links to other sites and third party content. STANNP is not responsible for the security or privacy provided by such third parties.
J. Personal Information About Children Under 18
K. Contractual or Statutory Requirements
L. Failure to Provide Personal Information
You can always opt not to disclose information to STANNP. If and to the extent you elect to do so, that decision will affect STANNP's ability to communicate with, provide Services to, employ, or otherwise interact with you.
M. Automated Decision Making
STANNP does not rely on automated decision making, including profiling, that will produce legal effects concerning or similarly significantly affecting any individual. Pursuant to Article 4(4) of the GDPR, profiling is defined as “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse [sic] or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior [sic], location or movements.”
N. Transfer of Data
If and to the extent that STANNP transfers Personal Information from another country into the United States, STANNP does so in compliance with the Privacy Laws of the originating country.
P. Contact Information
Q. Effective Date