1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 8, below;

“Our Site” means this website, [pulloutpens.com]

“We/Us/Our” means Pulloutpens.

2. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

3.When do we collect information?

We collect information from you when you register on our site, place an order, subscribe to a newsletter, respond to a survey, fill out a form, Use Live Chat or enter information on our site.

4.What Data Do We Collect?

Some data will be collected automatically by Our Site , other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

  • Name
  • Business/company name
  • Profession;
  • Contact information such as email addresses and telephone numbers;
  • Billing address, city, state, postal code and Country
  • Financial information such as credit / debit card numbers;
  • IP address (automatically collected);
  • A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);

5. How Do We Use Your Data?

All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 5, below.
We use your data to provide the best possible products and services to you. This includes:

  • Providing and managing your Account;
  • Providing and managing your access to Our Site;
  • Personalizing and tailoring your experience on Our Site;
  • Supplying Our products and services to you;
  • Personalizing and tailoring Our products and services for you;
  • Responding to communications from you;
  • Supplying you with informational emails e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by Insert Description of Unsubscription Method;
  • Market research;
  • Analyzing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR standard postal service with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

  • You have given consent to the processing of your personal data for one or more specific purposes;
  • Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
  • Processing is necessary for compliance with a legal obligation to which we are subject;
  • Processing is necessary to protect the vital interests of you or of another natural person;
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
  • Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6.How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

       To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.

       To improve our website in order to better serve you.

       To allow us to better service you in responding to your customer service requests.

       To administer a contest, promotion, survey or other site feature.

       To quickly process your transactions.

       To ask for ratings and reviews of services or products

       To follow up with them after correspondence (live chat, email or phone inquiries)

7.How do we protect your information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

8.Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

       Help remember and process the items in the shopping cart.

       Understand and save user’s preferences for future visits.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

If users disable cookies in their browser:
If you turn cookies off, Some of the features that make your site experience more efficient may not function properly.Some of the features that make your site experience more efficient and may not function properly.

9.Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

10.Third-party links

We do not include or offer third-party products or services on our website.

11.Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users.

We use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

       Remarketing with Google AdSense

       Google Display Network Impression Reporting

       Demographics and Interests Reporting

       DoubleClick Platform Integration

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on. google.com/ads/preferences

12.California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

       On our Privacy Policy Page

Can change your personal information:

       By emailing us

       By logging in to your account

       By chatting with us or by sending us a support ticket

13.How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

14.Does our site allow third-party behavioral tracking?

It’s also important to note that we do not allow third-party behavioral tracking

15.COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

16.Do we let third-parties, including ad networks or plug-ins collect PII from children under 13?

We do not specifically market to children under the age of 13 years old.

17.Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify the users via in-site notification

       Within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

18.CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

       Send information, respond to inquiries, and/or other requests or questions

       Process orders and to send information and updates pertaining to orders.

       Send you additional information related to your product and/or service

       Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

       Not use false or misleading subjects or email addresses.

       Identify the message as an advertisement in some reasonable way.

       Include the physical address of our business or site headquarters.

       Monitor third-party email marketing services for compliance, if one is used.

       Honor opt-out/unsubscribe requests quickly.

       Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us,

 and we will promptly remove you from ALL correspondence.

19. Summary of Your Rights under GDPR

Under the GDPR, you have:

  • the right to request access to, deletion of or correction of, your personal data held by Us;
  • the right to complain to a supervisory authority;
  • be informed of what data processing is taking place;
  • the right to restrict processing;
  • the right to data portability;
  • object to processing of your personal data;
  • rights with respect to automated decision-making and profiling (see section 20 below).

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 21 below.

20. Automated Decision-Making and Profiling

In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

The right described in section 20.1 does not apply in the following circumstances:

  • The decision is necessary for the entry into, or performance of, a contract between the You and Us;
  • The decision is authorised by law; or
  • You have given you explicit consent.

Where We use your personal data for profiling purposes, the following shall apply:

  • Clear information explaining the profiling will be provided, including its significance and the likely consequences;
  • Appropriate mathematical or statistical procedures will be used;
  • Technical and organizational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  • All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

21.Contacting Us

If there are any questions regarding this privacy policy, please contact us by email