=PRIVACY, SECURITY AND TRANSPARENCY


Our privacy statement, contained in the pages that follow, serves to give notice about the types of personal information we collect, how we use it, who we share it with and why, and what we do to try to protect it. We delve into those matters in a fair amount of detail in the pages that follow. We encourage you to read them carefully. In the meantime, we provide a quick overview below.

 

Summary of how we handle Personal Information

         What do we collect?

 

We collect and retain certain personal information from four different groups of data subjects encompassing: our workforce, vendors, customers and those who visit and use our online and mobile resources. Our privacy statement applies mostly to that last group, from which we collect very little information unless it is voluntarily submitted to us. You can read here to learn about the categories of personal information we collect from all four groups of data subjects.

           Why do we use it?

 

We use personal information received from visitors and users of our online and mobile resources to communicate directly with them. Personal information collected from our workforce is used to fulfill our human resources commitments and in furtherance of our legal obligations as an employer, while personal information collected from our customers is used as needed to carry out the contracts we have with them. We provide further detail about our use of personal information here.

         When do we share it?

 

We share personal information when needed to fulfill our legal obligations and when our vendors and business partners need it to perform under the contracts we have with them. We provide further detail about our sharing of personal information here. We do not sell or rent any personal information from any group of data subjects to third party data brokers or marketing companies.

        How do we protect it?

 

We've invested heavily in a Security Program that addresses both technical and operational matters. Our program includes an incident response and management and vendor oversight components. You can read about those components here and here.

 

        Your Privacy Choices and Rights

 

You do not have to provide personal information to enjoy most of the features of our online and mobile resources. Moreover, you can opt out of certain activities like newsletters and announcements. You can learn more about that here.

 

 

Contacting Our Privacy Office

 

If you have any questions about our privacy and data security policies, procedures and practices, including anything we say in this privacy statement, we encourage you to contact our Privacy Office.

 

Nano Media Inc.
PO Box 3540

Silver Springs, NV 89429
contact@getnanosocks.com
1-888-205-9526

 


 

This privacy statement was amended as of May 3rd, 2020 and is effective as of that date. The English language version of this privacy statement is the controlling version regardless of any translation you may attempt.

 

NAVIGATING THROUGH THIS STATEMENT

 

You can use the links below to navigate to areas of this statement that apply specifically to you, or which may otherwise be of interest:

 

Some Important Vocabulary

What Personal Information Do We Collect?

How Do We Use the Personal Information We Collect?

When/With Whom Do We Share Personal Information?

How Do We Protect Collected Personal Information?

Your Rights And Options

Children's Privacy

Changes To This Privacy Statement

Contacting Us

 

SOME IMPORTANT VOCABULARY

 

Although not itself a contract, this privacy statement is an important document that explains how we address some of our legal obligations, and your related legal rights, involving personal information. Clarity is, therefore, important. We'll use this section to let you know about some words that have special meanings whenever you see them in this statement. Let's start with the word statement itself: when we reference this statement, this privacy statement and our statement, we mean the Privacy and Data Security Statement you are reading now. Wherever we say Company, we, us, or our, we mean Company Legal Name. We use the words you and your to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 18. This age requirement is discussed in more detail later in this statement here. We also want to be very clear about exactly what parts of the Company corporate enterprise are covered by, and adhere to the policies and procedures explained in this statement.

 

When we talk about our online and mobile resources, we mean all websites, portals or other features we operate to allow you to interact with us and our systems, as well as the mobile apps we've created and distributed to let you interact with the content we provide. An affinity action is when you follow us, like us or take a similar or analogous action on our external social media presence.

Finally, and perhaps most importantly, when we refer to personal information, we mean information that can be used to identify or easily be linked to you. The privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of the data subjects they protect.

 

WHAT PERSONAL INFORMATION DO WE COLLECT?

 

We collect personal information from four groups of data subjects:

 

        visitors to, and users of, our online and mobile resources

        current members of our workforce and those who apply for posted jobs

        our third party vendors and business partners

        our customers

 

The categories of information we collect from each of these groups differs. As you may have noticed, it's possible that the same person could fall into more than one group. For instance, someone who is a customer might also work for one of our vendors. Or someone who works for us might, on their day off, visit one of our general websites. We explain below the different categories of personal information we collect from each group of data subject.

 

 

 

Visitors and Users of our Online and Mobile Resources

 

If you visit and/or use our online and mobile resources, we collect and retain a very limited amount of personal information through automated/technical means. We describe that automatic collection here. In addition to that, if you choose to participate in, or make use of certain activities and features available via our online and mobile resources, you will need to provide us with information about yourself. We describe that type of voluntary submission immediately below. By using our online and mobile resources, you are signifying to us that you agree with this section of our privacy statement and that we may use and disclose your information as described.

Voluntarily Submitted Information.

Here are some of the ways you voluntarily give us your personal information. The types of personal information you will be submitting to us in these situations is almost always limited to identifiers such as your name, email address, mailing address and phone number. You can read about how we use that personal information here.

 

        Emails and Texts If you choose to send us an email from our contact us link or a similar link, you will be giving us your email address and any other personal information that may be in your message or attached to it. The same is true if you send us a text message. 

 

        Creating Accounts; Signing up for Newsletters If we make an account creation feature available to the general public (that is, to visitors/users who are not our customers or workforce members) you will be giving us at least your email address and potentially other identifiers. The same is true if you sign up to receive a newsletter or other informational or marketing material we publish.

 

        Registering for Events When you register for events, conferences or programs we ourselves may host (rather than outsource to a third party event manager with its own privacy policies), you will be submitting the types of identifiers described above. If the event requires a fee, we may also ask you to submit credit card or other financial information.

 

        Social Media and Community Features Some of our online and mobile resources may offer social media-like community features letting users post or upload messages, comments, and/or image or other files and materials. If you choose to make use of these features the information you post, including your screen name and any other personal information, will be in the public domain and not covered/protected by this statement.

 

        Customer Portals and Job Applicants Some of our online and mobile resources are used to help us serve our customers and allow candidates to apply for available jobs. We discuss personal information submitted in those situations elsewhere in this statement such as here and here.

 

If you prefer we not receive the above-described personal information, please don't submit it. This means you shouldn't participate in the applicable activities on, or use the applicable features available from our online and mobile resources. Such participation and use is strictly your choice. By not participating, you may limit your ability to take full advantage of the online and mobile resources, but most of the content in our online and mobile resources will still be available to you.

 

Automatically Collected Information.

When you visit or use our online and mobile resources, basic information about your internet/electronic activity is automatically collected through your browser via tracking technologies, such as cookies. As just about everyone knows by now, cookies are small text files downloaded onto your computer or mobile device. Cookies allow us to collect your IP address and recognize your computer or mobile device and store some information about your preferences for using our online and mobile resources or past actions, such as:

 

        the type of browser and operating system you use

        the date and time and length of your visit

        the pages visited, graphics viewed and any documents downloaded

        links to other sites you accessed from our online and mobile resources or used to navigate to our online and mobile resources

 

Additional information about cookies and tracking technologies is available here.

 

If you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us certain information such as uniquely identifiable mobile device information. That, in turn, allows us to collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone service providers also operate systems that pinpoint the physical location of devices and we may receive this geolocation data as well.

 

Finally, when you use our online and mobile resources, we may allow third party service providers to place their own cookies or similar technologies in order to engage in the same types of collection we describe above. For example, some Company companies covered by this statement use third party web analytics services such as those offered by Google Analytics. For more information on how Google specifically uses this data, go to www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout.

 

User Beware: External Sites, Apps, Links and Social Media.

Some Company companies maintain a presence on one or more external social media platforms such as Twitter, Facebook, YouTube and LinkedIn. We may further allow the community features of our online and mobile resources to connect with, or be viewable from, that external social media presence. Similarly, our online and mobile resources may contain links to other websites or apps controlled by third parties.

 

We are not responsible for either the content on, or the privacy practices of, social media platforms, or any third party sites or apps to which we link. Those apps, sites and platforms are not controlled by us and therefore have their own privacy policies and terms of use. To be clear: neither this statement nor the terms of use appearing on or in any of our online and mobile resources apply to our social media presence or any third party sites or apps to which we may link. That means even if you take an affinity action on our specific social media presence, and identifiers about you are automatically collected and given to us as a result, that collection and transfer is governed by the privacy policies and other terms of the applicable social media platform and are not our responsibility. If you have questions about how those apps, sites and platforms collect and use personal information, you should carefully read their privacy policies and contact them using the information they provide.

 

Personal Information we collect from our Customers

 

We necessarily collect a lot more personal information from our customers and those who apply to be customers than we do from others.

 

Customers enter into a contract with us. That contract is separate from this statement and has its own terms and conditions for notice of collection and governing our overall confidentiality, data privacy and data security obligations. As a result, those terms, and not this statement, apply to the personal information of customers.

 

For those who apply to become customers, we provide notice of what personal information we collect on the proprietary documents that are part of our application process, or the apps and portals we operate for such purpose, doing so via confidential Company terms and conditions published thereon. In some cases, customer applicant data will be collected by one of our business partners and shared with us. In those situations, the legal responsibility to provide notice rests with that business partner, not Company.

 

Personal Information we collect from our Workforce and Job Applicants

 

We collect and retain the types of professional or employment related personal information you would expect a U.S. employer to have about its U.S. workforce such as name, age, home address, and personal information for payroll, tax and benefits. When the law allows or requires (such as for compliance with equal opportunity/non-discrimination laws) we may also collect characteristics of protected classifications such as race, gender, and ethnicity. Similarly, when someone applies for an open job position, including via portals or other online and mobile resources, we collect the personal information we need, and which the law allows, to evaluate their applications.

 

We provide notice of what personal information we collect from our workforce/applicants in our confidential human resources manuals and other documentation, or on the proprietary apps and portals we operate for such purpose doing so via confidential Company terms and conditions published thereon. In some cases, portals and apps may be operated by third parties who transfer the personal information to us. In those situations, the legal responsibility to provide notice usually rests with the third party, not Company. You can read about how we use the personal information we collect from our workforce and job applicants here.

 

Personal Information we collect from Vendors and Business Partners

 

Like all large corporate enterprises, we buy goods and services, lease equipment and office space and attend industry events. In doing so, we interact with many existing and potential vendors and business partners from whom we necessarily collect certain personal information in connection with our contractual and business relationships. Typically, the categories of personal information collected in those cases will be limited to what is often referred to as minimum business contact information such as name, business title, business address and business email. As a result, if legally required, we make a reasonable effort to provide notice at the point of collection, or address the question of notice in the applicable business contract.

 

HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?

 

We use personal information we collect only in the manner and through the means allowed by applicable law. That means we determine whether we have a lawful basis/legitimate business purpose to use your personal information before doing so. As stated in applicable law, such lawful bases/legitimate business purposes include receiving express consent, operating our business, performing a contract, and complying with a legal obligation. More specifically, we use the personal information of each group of data subjects as follows:

 

Visitors and Users of our Online and Mobile Resources

 

We use the automatically collected personal information described here to compile generic reports about popular pages/features of our online and mobile resources, and to see how users are accessing our online and mobile resources and in some cases (such as affinity actions) send materials to you. We use the personal information you voluntarily submitted, as described here, to respond back directly to you and/or send you the information you requested or about which you inquired. We also may use any such personal information you provide to customize our programs and newsletters to make them more relevant to you. We do not sell or rent personal information automatically collected by, or which you voluntarily provide when using our online and mobile resources.

 

Our Customers

 

We use personal information collected from our customers to administer their policies and process their claims. As mentioned above, customers enter into confidential contracts with us and those contracts have their own terms and conditions describing the manner and means of our use of customer personal information. As a result, those terms and not this statement, apply to our use of the personal information of customers. We use personal information collected from customer applicants to evaluate their applications and underwrite and provide premium quotes. We provide notice of our scope of use via confidential Company documents or by publication on the proprietary apps and portals we operate for such purpose.

 

Our Workforce and Job Applicants

 

We use personal information collected from our workforce to operate our business, perform our duties as an employer, and fulfill our commitments to workforce members (such as benefits administration). We use personal information collected from job applicants to evaluate their candidacy and process their applications. We describe our use of workforce and job applicant personal information in greater detail in confidential Company human resource policy documents or by publishing such policies on the proprietary workforce/applicant portals and apps we operate.

 

Vendors and Business Partners

 

We use the personal information collected from our vendors and business partners (which, again, is largely minimum business contact information) to manage, administer and perform under our contracts with them, or share information about our products. We also may from time-to-time use personal information about their individual personnel to perform background checks on those who are provided access to our facilities or technology networks so that we can help protect the personal information of others stored thereon. We describe our use of vendor and business partner personal information in greater detail in our confidential contracts with those parties.

 

WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION?

 

We may share your personal information as described below. This sharing applies to the personal information of all four groups of data subjects described here.

 

Affiliates

 

We may share personal information to other companies within Company who will use such information in the same way as we can under this statement.

 

Legal Requirements

 

We may disclose personal information to government authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including responding to court orders and subpoenas.

To Prevent Harm

 

We also may disclose such information when we have reason to believe that someone is causing injury to or interference with our rights or property, or harming or potentially harming other persons or property.

 

Business Sale/Purchase

 

If Company or any of the companies covered by this statement, or any of their affiliates or subsidiaries, sell or transfer all or substantially all of their assets, equity interests or securities, or are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, divestiture, consolidation, or liquidation, personal information may be one of the transferred assets.

 

 

Vendors and Business Partners

 

We also share personal information with those of our vendors and business partners who need it to perform under the contracts we have with them. As part of our Security Program, we have adopted standards for those vendors and business partners who receive personal information from us. We attempt to bind such vendors and business partners to those standards via written contracts. Such standards include expectations that when we share personal information with our vendors and business partners, they will comply with all applicable privacy and data security laws and regulations and our Security Program, and will contractually require and cause their subcontractors and agents to do the same. We further attempt to contractually restrict what our vendors and business partners can do with the personal information we provide to them such that it:

 

        is used only to the minimum extent necessary to carry out the business purpose for which it was provided

 

        is not disclosed to anyone else without our consent or under our instruction

 

        remains, as between us and the applicable vendor or business partner, our property

        is not transferred out of the United States without our consent

 

For any personal information our vendors and business partners process or store at their own locations, we further expect them to use technology infrastructure meeting, at least at the facilities level, minimum recognized standards for security controls. Such recognized standards include those published by the International Standards Organization, the National Institute of Standards and Technology the AT 101 standards (for data security matters) published by the American Institute of Certified Public Accountants, the Payment Card Industry Security Standards Council, or any reasonably equivalent standards.

 

Please note, however, that we cannot guarantee that all of our vendors and business partners will agree to the above-described contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply.

 

HOW DO WE PROTECT COLLECTED PERSONAL INFORMATION?

 

Our Data Security Program

 

We have adopted, implemented and maintain an enterprise-wide corporate information security and privacy program that includes technical, organizational, administrative, and other security measures designed to protect, as required by applicable law (including all those described above), against reasonably anticipated or actual threats to the security of your personal information (the Security Program). Our Security Program was created by reference to widely recognized industry standards such as those published by the International Standards Organization, National Institute of Standards and Technology and the Payment Card Industry Security Standards Council. It includes, among many other things, procedures for assessing the need for, and as appropriate, either employing encryption and multi-factor authentication or using equivalent compensating controls. We therefore have every reason to believe our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks to the personal information we collect. We further periodically review and update our Security Program, including as required by applicable law.

 

Our Incident Response and Management Plan

 

Despite the significant investment weve made in, and our commitment to, the Security Program including enforcement of our third party oversight procedures, we cannot guarantee that your personal information, whether during transmission or while stored on our systems, otherwise in our care, or the care of our vendors and business partners, will be free from either failed or successful attempts at unauthorized access or that loss or destruction will never occur. Except for our duty to maintain the Security Program under applicable law, we therefore necessarily disclaim, to the maximum extent the law allows, any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications including personal information.

 

All that said, as part of our Security Program, we have specific incident response and management procedures that are activated whenever we become aware that your personal information was likely to have been compromised. Those procedures include mechanisms to provide, when circumstances and/or our legal obligations warrant, notice to all affected data subjects within the timeframes required by law, as well as to give them such other mitigation and protection services (such as the credit monitoring and ID theft insurance) as may be required by applicable law. We further require, as part of our vendor and business partner oversight procedures, that such parties notify us immediately if they have any reason to believe that an incident adversely affecting personal information we provided to them has occurred.

 

YOUR RIGHTS AND OPTIONS

 

If we are using your personal information to send you marketing materials, such as newsletters or product alerts via text or email, you may opt out by following the opt-out instructions in the email or other communication (e.g., by responding to the text with STOP). In addition, certain of our online and mobile resources will provide a centralized opt-out link allowing you to opt out of any programs in which you may have enrolled using that particular online or mobile resource. When we receive your request, we will take reasonable steps to remove your name from our distribution lists, but it may take time to do so. You may still receive materials for a period of time after you opt out. In addition to opting out, you have the ability to access, amend and delete your personal information by contacting us using the contact information below. Opting out of or changing affinity actions or other submissions or requests made on our third party social media platform, will likely require that you do so directly on that platform as we do not control their procedures.

 

Some browsers have a do not track feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not specifically respond to browser do not track signals.

 

CHILDRENS PRIVACY

 

Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from children under the age of 13. We take those age-related requirements very seriously, and, consistent with them, do not intend for our online and mobile resources to be used by children under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from minors under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to us via our online and mobile resources, we will delete that information and not use it for any purpose whatsoever. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.

 

CHANGES TO THIS PRIVACY STATEMENT

 

We reserve the right to change or update this statement from time to time. Please check our online and mobile resources periodically for such changes since all information collected is subject to the statement in place at that time. Typically, we will indicate the effective/amendment date at the beginning of this statement. If we feel it is appropriate, or if the law requires, well also provide a summary of changes weve made near the end of the new statement.

 

CONTACTING US

 

If you have questions about our privacy statement or privacy practices, please contact Our Privacy Office:

 

Nano Media Inc.
PO Box 3540

Silver Springs, NV 89429
contact@getnanosocks.com
1-888-205-9526