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Global Data Protection Policy
Sammann Company, Inc. d/b/a Peepers by PeeperSpecs
Global Data Protection Policy
Your privacy is very important to us. We have developed this Global Data Protection Policy in order for you to understand how we collect, use, store, share, transmit, transfer, delete or otherwise process (collectively “Process”) your Personal Data. This Global Data Protection Policy describes the measures we take to ensure the protection of your Personal Data. We also tell you how you can reach us to answer any questions you may have about data protection.
SCOPE
The Global Data Protection Policy applies to the global organization of Sammann Company, Inc. d/b/a Peepers by PeeperSpecs (hereafter “Sammann” or “us”) for all dimensions and activities, in all geographies where we operate when European data protection law, namely the General Data Protection Regulation (or “GDPR”) apply.
This policy applies to the Processing of Personal Data collected by Sammann, directly or indirectly, from all individuals including, but not limited to Sammann’s current, past or prospective job applicants, employees, clients, consumers, children, suppliers/vendors, contractors/subcontractors, shareholders or any third parties, with “Personal Data” being defined as any data that relates to an identified or identifiable individual or a person who may be identified by means reasonably likely to be used.
In this Policy, “you” and “your” means any covered individual. “We”, “us”, “our” and “Sammann” means Sammann Company, Inc. d/b/a Peepers by PeeperSpecs.
COLLECTION AND PROCESSING USE OF YOUR PERSONAL DATA
COMPLIANCE WITH THE EUROPEAN DATA PROTECTION LAW AND ANY ADDITIONAL APPLICABLE LOCAL DATA PROTECTION LAW
We are committed to complying with any applicable legislation relating to Personal Data and we shall ensure that Personal Data is collected and processed in accordance with provisions of the European data protection law and other applicable local law, if any.
LAWFULNESS, FAIRNESS AND TRANSPARENCY
We do not collect or process Personal Data without having a lawful reason to do so. We may have to collect and process your Personal Data where necessary for the performance of a contract to which you are party, or when it is necessary for compliance with a legal obligation to which we are subject or where required, with your prior consent. We may also collect and process your Personal Data for Sammann’s legitimate interests except where such interests are overridden by your interests or fundamental rights and freedoms.
When collecting and processing your Personal Data, we will provide you with a fair and full information notice or privacy statement about who is responsible for the processing of your Personal Data, for what purposes your Personal Data are processed, who the recipients are, what your rights are and how to exercise them, etc., unless it is impossible or it requires disproportionate efforts to do so.
When required by applicable law, we will seek your prior consent (e.g. before collecting any Sensitive Personal Data).
LEGITIMATE PURPOSE, LIMITATION AND DATA MINIMIZATION
Your Personal Data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
When Sammann acts for its own purposes, your Personal Data is processed mainly for, but not limited to, the following purposes:
DATA ACCURACY AND STORAGE LIMITATION
Sammann will keep Personal Data that is processed accurate and, where necessary, up to date. Also, we will only retain Personal Data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements and, where required for Sammann to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. If you want to learn more about our specific retention periods for your Personal Data established in our retention policy, you may contact us at peeps@peeprers.com.
Upon expiration of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
SECURITY OF YOUR PERSONAL DATA
We implement appropriate technical and organizational measures to protect Personal Data against accidental or unlawful alteration or loss, or from unauthorized, use, disclosure or access. We take, when appropriate, all reasonable measures based on Privacy by design and Privacy by default principles to implement the necessary safeguards and protect the Processing of Personal Data.
DISCLOSURE OF YOUR PERSONAL DATA
We may share your information (i) among our various subsidiaries, divisions, affiliates, parent organizations, and brands; (ii) with third parties, financial institutions, and others who perform services on our behalf; (iii) with any successor-in-interest to Sammann, or otherwise in connection with a merger, sale, or transfer of all or part of our business operations; (iv) in response to subpoenas, investigative requests (with or without subpoena) and other legal processes; (v) to exercise our legal rights and defend against legal claims; and (vi) for other reasons as may be described to Users, such as working with a marketing partner to provide them with a program or service.
INTERNATIONAL PERSONAL DATA TRANSFERS
European data protection law does not allow the transfer of Personal Data to third countries outside the European Economic Area (EEA) that do not ensure an adequate level of data protection.
COOKIES
Our Websites may use “cookies.” Cookies are portions of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a website.
We will let you know when you visit our websites what types of cookies we use and how to disable such cookies. When required by law, you will have the ability to visit our websites and refuse the use of cookies at any time on your computer. For more details, please consult our Cookies policies.
YOUR RIGHTS
Sammann is committed to ensure protection of your rights under applicable laws. You will find below a table summarizing your different rights:
To exercise these rights, you can complete the Request form at the bottom of this policy and send it to peeps@peeprers.com.
You can choose to lodge a Complaint with the Data Protection Supervisory Authority in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages.
You have also the right to lodge your Complaint before the courts where the Sammann entity has an establishment or where you have your habitual residence.
CHILDREN
Children merit specific protection with regard to their Personal Data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the Processing of Personal Data. Such specific protection should, in particular, apply to the use of Personal Data of children for the purposes of marketing or creating personality or user profiles and the collection of Personal Data with regard to children when using services offered directly to a child.
We do not collect and process Children’s Personal Data without the consent of the holder of parental responsibility where required. In particular, we do not promote or market our services to Children, except for specific services and upon the consent of the holder of parental responsibility. If you believe that we have mistakenly collected a Children's Personal Data, please notify us using the contact details provided below.
UPDATE
We may update this policy from time to time as our business changes or legal requirements change. If we make any significant changes to this policy, we will post a notice on our website when the changes go into effect, and where appropriate, send a direct communication to you about the change.
CONTACT US
If you have questions, comments and requests regarding this policy you can send them to Sammann as follows:
Phone: 1-800-348-2508
Website: www.peepers.com
Email: peeps@peepers.com
Postal Address: 9935 E US HWY 12
Michigan City, IN 46360
(Name (Last, First))............................................................................................................................
(Telephone number)...........................................................................................................................
(Email address).................................................................................................................................
(Postal address)................................................................................................................................
Please indicate your preferred method of contact:
Email Home Address:
In order to help us identify systems that may contain information about you, please check the boxes below that describe your relationship with Sodexo:
☐ Individual – Consumer
☐ Other – please describe:
......................................................................................................................................................
......................................................................................................................................................
If your information may be under another name, please provide that name and reason for the change:
......................................................................................................................................................
......................................................................................................................................................
......................................................................................................................................................
......................................................................................................................................................
We may request from you a certified copy of a valid official identification documentation to allow us to verify your name and address (e.g. valid passport or identity card).
If you request to access your Personal Data or request data portability, please specify the Personal Data which is subject to the request and confirm that they may be sent by email to the address above or, if technically feasible, to the address of a new Controller as set out below, for the data portability request:
......................................................................................................................................................
......................................................................................................................................................
If you request rectification of your Personal Data, please specify below the data to be rectified, and provide the justification for such request:
......................................................................................................................................................
......................................................................................................................................................
If you request that the Processing of your Personal Data is restricted please specify the processing in issue, and provide the justification for such request:
......................................................................................................................................................
......................................................................................................................................................
If you request the erasure of your Personal Data, please specify below the Personal Data to be deleted and provide the justification for such request:
......................................................................................................................................................
......................................................................................................................................................
If you object to the processing of your Personal Data, please specify below the Personal Data you object to us processing and provide the justification for such objection:
......................................................................................................................................................
......................................................................................................................................................
The information collected in this form is intended to enable Sammann to respond to your Request.
Global Data Protection Policy
Your privacy is very important to us. We have developed this Global Data Protection Policy in order for you to understand how we collect, use, store, share, transmit, transfer, delete or otherwise process (collectively “Process”) your Personal Data. This Global Data Protection Policy describes the measures we take to ensure the protection of your Personal Data. We also tell you how you can reach us to answer any questions you may have about data protection.
SCOPE
The Global Data Protection Policy applies to the global organization of Sammann Company, Inc. d/b/a Peepers by PeeperSpecs (hereafter “Sammann” or “us”) for all dimensions and activities, in all geographies where we operate when European data protection law, namely the General Data Protection Regulation (or “GDPR”) apply.
This policy applies to the Processing of Personal Data collected by Sammann, directly or indirectly, from all individuals including, but not limited to Sammann’s current, past or prospective job applicants, employees, clients, consumers, children, suppliers/vendors, contractors/subcontractors, shareholders or any third parties, with “Personal Data” being defined as any data that relates to an identified or identifiable individual or a person who may be identified by means reasonably likely to be used.
In this Policy, “you” and “your” means any covered individual. “We”, “us”, “our” and “Sammann” means Sammann Company, Inc. d/b/a Peepers by PeeperSpecs.
COLLECTION AND PROCESSING USE OF YOUR PERSONAL DATA
COMPLIANCE WITH THE EUROPEAN DATA PROTECTION LAW AND ANY ADDITIONAL APPLICABLE LOCAL DATA PROTECTION LAW
We are committed to complying with any applicable legislation relating to Personal Data and we shall ensure that Personal Data is collected and processed in accordance with provisions of the European data protection law and other applicable local law, if any.
LAWFULNESS, FAIRNESS AND TRANSPARENCY
We do not collect or process Personal Data without having a lawful reason to do so. We may have to collect and process your Personal Data where necessary for the performance of a contract to which you are party, or when it is necessary for compliance with a legal obligation to which we are subject or where required, with your prior consent. We may also collect and process your Personal Data for Sammann’s legitimate interests except where such interests are overridden by your interests or fundamental rights and freedoms.
When collecting and processing your Personal Data, we will provide you with a fair and full information notice or privacy statement about who is responsible for the processing of your Personal Data, for what purposes your Personal Data are processed, who the recipients are, what your rights are and how to exercise them, etc., unless it is impossible or it requires disproportionate efforts to do so.
When required by applicable law, we will seek your prior consent (e.g. before collecting any Sensitive Personal Data).
LEGITIMATE PURPOSE, LIMITATION AND DATA MINIMIZATION
Your Personal Data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
When Sammann acts for its own purposes, your Personal Data is processed mainly for, but not limited to, the following purposes:
- To respond to your request or inquiry and to fill their order(s);
- To understand the use of our Website (the “Site”, improve the content of the Site, customize the shopping experience for you, and otherwise improve our products, services, the Site and your online experience, including through using the collection practices described herein;
- To notify you of changes to the Sites, new products and services, and for any other legitimate and lawful business purpose, including to notify you of changes to our Terms and Conditions of Use or other terms that may impact your use of the Sites;
- To protect the security or integrity of the Sites, Sammann, our you; and
- To determine our your browser, recognize new visitors or existing users, and better understand you (including by using tracking tools).
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
DATA ACCURACY AND STORAGE LIMITATION
Sammann will keep Personal Data that is processed accurate and, where necessary, up to date. Also, we will only retain Personal Data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements and, where required for Sammann to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. If you want to learn more about our specific retention periods for your Personal Data established in our retention policy, you may contact us at peeps@peeprers.com.
Upon expiration of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
SECURITY OF YOUR PERSONAL DATA
We implement appropriate technical and organizational measures to protect Personal Data against accidental or unlawful alteration or loss, or from unauthorized, use, disclosure or access. We take, when appropriate, all reasonable measures based on Privacy by design and Privacy by default principles to implement the necessary safeguards and protect the Processing of Personal Data.
DISCLOSURE OF YOUR PERSONAL DATA
We may share your information (i) among our various subsidiaries, divisions, affiliates, parent organizations, and brands; (ii) with third parties, financial institutions, and others who perform services on our behalf; (iii) with any successor-in-interest to Sammann, or otherwise in connection with a merger, sale, or transfer of all or part of our business operations; (iv) in response to subpoenas, investigative requests (with or without subpoena) and other legal processes; (v) to exercise our legal rights and defend against legal claims; and (vi) for other reasons as may be described to Users, such as working with a marketing partner to provide them with a program or service.
INTERNATIONAL PERSONAL DATA TRANSFERS
European data protection law does not allow the transfer of Personal Data to third countries outside the European Economic Area (EEA) that do not ensure an adequate level of data protection.
COOKIES
Our Websites may use “cookies.” Cookies are portions of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a website.
We will let you know when you visit our websites what types of cookies we use and how to disable such cookies. When required by law, you will have the ability to visit our websites and refuse the use of cookies at any time on your computer. For more details, please consult our Cookies policies.
YOUR RIGHTS
Sammann is committed to ensure protection of your rights under applicable laws. You will find below a table summarizing your different rights:
| RIGHT OF ACCESS AND RECTIFICATION | You can request access to your Personal data. You may also request rectification of inaccurate Personal data, or to have incomplete Personal data completed. |
| RIGHT TO ERASURE | Your right to be forgotten entitles you to request the erasure of your Personal Data in cases where: 1. the data is no longer necessary for the purpose for which it was collected; 2. you choose to withdraw your consent; 3. you object to the processing of your Personal Data; 4. your Personal Data has been unlawfully processed; 5. there is a legal obligation to erase your Personal Data; 6. erasure is required to ensure compliance with applicable laws. |
| RIGHT TO RESTRICTION OF PROCESSING | You may request that processing of your Personal Data be restricted in the cases where: 1. you contest the accuracy of your Personal Data; 2. Sammann no longer needs your Personal Data for the purposes of the processing; 3. You have objected to processing for legitimate reasons |
| RIGHT TO DATA PORTABILITY | You can request, where applicable, the portability of your Personal Data that you have provided to Sammann, in a structured, commonly used, and machine-readable format you have the right to transmit this data to another Controller without hindrance from Sodexo where: 1. the processing of your Personal Data is based on consent or on a contract; and 2. the processing is carried out by automated means. You can also request that your Personal Data be transmitted to a third party of your choice (where technically feasible). |
| RIGHT TO OBJECT TO PROCESSING | You may object (i.e. exercise your right to “opt-out”) to the processing of your Personal Data particularly in relation to profiling or to marketing communications. When we process your Personal Data on the basis of your consent, you can withdraw your consent at any time. |
| RIGHT TO LODGE A COMPLAINT | You can choose to lodge a Complaint with the Data Protection Supervisory Authority in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages. You have also the right to lodge your Complaint before the courts where Samman is located (Michigan City, Indiana, United States of America). |
To exercise these rights, you can complete the Request form at the bottom of this policy and send it to peeps@peeprers.com.
You can choose to lodge a Complaint with the Data Protection Supervisory Authority in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages.
You have also the right to lodge your Complaint before the courts where the Sammann entity has an establishment or where you have your habitual residence.
CHILDREN
Children merit specific protection with regard to their Personal Data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the Processing of Personal Data. Such specific protection should, in particular, apply to the use of Personal Data of children for the purposes of marketing or creating personality or user profiles and the collection of Personal Data with regard to children when using services offered directly to a child.
We do not collect and process Children’s Personal Data without the consent of the holder of parental responsibility where required. In particular, we do not promote or market our services to Children, except for specific services and upon the consent of the holder of parental responsibility. If you believe that we have mistakenly collected a Children's Personal Data, please notify us using the contact details provided below.
UPDATE
We may update this policy from time to time as our business changes or legal requirements change. If we make any significant changes to this policy, we will post a notice on our website when the changes go into effect, and where appropriate, send a direct communication to you about the change.
CONTACT US
If you have questions, comments and requests regarding this policy you can send them to Sammann as follows:
Phone: 1-800-348-2508
Website: www.peepers.com
Email: peeps@peepers.com
Postal Address: 9935 E US HWY 12
Michigan City, IN 46360
REQUEST FORM
Contact Information:(Name (Last, First))............................................................................................................................
(Telephone number)...........................................................................................................................
(Email address).................................................................................................................................
(Postal address)................................................................................................................................
Please indicate your preferred method of contact:
Email Home Address:
In order to help us identify systems that may contain information about you, please check the boxes below that describe your relationship with Sodexo:
☐ Individual – Consumer
☐ Other – please describe:
......................................................................................................................................................
......................................................................................................................................................
If your information may be under another name, please provide that name and reason for the change:
......................................................................................................................................................
......................................................................................................................................................
......................................................................................................................................................
......................................................................................................................................................
We may request from you a certified copy of a valid official identification documentation to allow us to verify your name and address (e.g. valid passport or identity card).
If you request to access your Personal Data or request data portability, please specify the Personal Data which is subject to the request and confirm that they may be sent by email to the address above or, if technically feasible, to the address of a new Controller as set out below, for the data portability request:
......................................................................................................................................................
......................................................................................................................................................
If you request rectification of your Personal Data, please specify below the data to be rectified, and provide the justification for such request:
......................................................................................................................................................
......................................................................................................................................................
If you request that the Processing of your Personal Data is restricted please specify the processing in issue, and provide the justification for such request:
......................................................................................................................................................
......................................................................................................................................................
If you request the erasure of your Personal Data, please specify below the Personal Data to be deleted and provide the justification for such request:
......................................................................................................................................................
......................................................................................................................................................
If you object to the processing of your Personal Data, please specify below the Personal Data you object to us processing and provide the justification for such objection:
......................................................................................................................................................
......................................................................................................................................................
The information collected in this form is intended to enable Sammann to respond to your Request.