Last Updated: 04/01/2021
- California Users. If your personal information (as defined below) is subject to the California Consumer Privacy Act, California Civil Code § 1798.100 et seq. (with any implementing regulations and as may be amended from time to time, “CCPA”), please see Additional Information for California Users below for additional disclosures, our notice at collection, and a description of your rights under the CCPA.
- Nevada Users. If your personal information is subject to the Nevada privacy law, please see Nevada Residents below for additional information.
Collection of Your Information
In general, we collect information, including personal information, when you use our Website or services and when you communicate or otherwise interact with us. When we use the term “personal information,” we mean any information about an individual from which that person can be directly or indirectly identified. There are instances where we invite or request individuals to provide us with their personal information through our Website or other methods; we may also collect some information automatically.
Depending on how you interact with us, you may provide us with personal information, including:
- Identifiers and Similar Information. Information including your first and last name, personal e-mail address, business e-mail address, postal address, date of birth, phone number, IP address, online identifiers, or other similar identifiers.
- Product or Commercial Information. Records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including the types of products purchased, date of purchase, or other product identifying information.
- Correspondence and Communications. Records of information provided by you when you contact us directly, apply for a job, respond to a survey, or interact with us on social media.
- Professional or Employment-Related Information. This information includes your occupation, employer, title, education, certifications, language skills, and memberships.
- Internet or other electronic network activity information. This information includes your browsing history and your interactions with our Website.
- Audio, electronic, or visual information. This information may include, for example, call recordings when you call our customer service line or otherwise contact us.
How We Collect Your Information
We collect some personal information directly when it is provided by you or your representative. Other personal information and other information may be collected automatically when you visit our Website or indirectly from other sources such as our service providers and vendors.
Depending on how you interact with us, we may collect personal information through various sources including:
- Directly from You. When you interact with us directly, we may collect personal information and other information about you. For example, we will collect personal information about you when you register on our Website, sign up to receive communications from us, contact (online or offline), use our services, or otherwise correspond with us directly.
- Service Providers. Our service providers may collect personal information from you when providing us services and/or acting on our behalf.
How We Use Your Information
We may use personal information and other information for a number of purposes, including the following:
- Provide You With Services. We may use your personal information to provide you with our services.
- To Communicate With You. We may use your personal information to respond to your requests and to provide you with information about our services. For example, if you send us an e-mail message requesting information about KEOLIS NORTH AMERICA, we will use your e-mail address and other information you supply to respond to your request.
- Managing and Operating our Website. To keep our Website updated and relevant, to develop our business, and to inform our marketing strategy.
- Prevention and Detection of Fraud. For the prevention and detection of fraud, money laundering, or other crimes or violations of legal and/or regulatory requirements, or for the purpose of responding to a binding request from a public authority or court.
- Processing Job Applications. When you apply for a job through our careers page or through another platform, we will collect your personal information to process your application and recommend you review any third-party platform’s privacy policies.
- Advertising. To provide you with information, products, or services we feel may interest you.
If we intend to use your personal information to inform you about other KEOLIS NORTH AMERICA services, we will notify you and give you an opportunity to decline to receive such communications.
Disclosure of Your Information
We do not sell your personal information. We do not share personal information with third parties except as necessary to carry out our business or as required by law or other legal processes, including in the following circumstances:
- Our Affiliates. We may share information within our family of affiliated companies so that we may provide offers from those companies that may be relevant to you, better understand your preferences, and improve our Website and services.
- With Your Consent. We may disclose your personal information for any other purpose with your consent.
- Business Transactions or Transfers. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
- Other Legal Requirements. We may disclose your personal information in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend our rights or property, to prevent or investigate possible wrongdoing in connection with our Website, to protect the personal safety of our users or the public, and to protect against legal liability.
We may use third-party services on our website, including Google Analytics and Google Tag Manager. We use Google Analytics to help us understand how people are using our Website. Google Analytics and Google Tag Manager have its own cookies that it uses to track and aggregate this information. To find out more about how Google collects and processes data, please click here. You can prevent the use of Google Analytics relating to your use of our Website by downloading and installing the browser plugin available here.
How Long We Keep Your Information
We take reasonable steps to keep your personal information accurate and complete. Under applicable law, you have certain rights relating to our collection and use of your personal information:
- Access and Correct Your Information. You can request to access to the personal information that we hold about you and to correct any information that is incomplete or wrong. You can make such a request by contacting us using the information provided below. Please include “Rights Request” in the subject line. We will maintain personal information in our database whenever we are required to do so by law, for necessary operational reasons, or to maintain uniform business practices. Please note that we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Transfers of Your Information
We are an international company with offices in the United States and Canada. To operate our business, we may send your personal information outside of your state, province, or country, including to the United States. This information may be subject to the laws of the countries where we send it. When we send your information across borders, we take steps to protect your information, and we try to only send your information to countries that have strong data protection laws.
The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We have technological and operational security policies and procedures in place to protect your personal information from loss, misuse, alteration, or unintentional destruction. Our personnel who have access to the data have been trained to maintain the confidentiality of such information.
Additional Information for California Residents
The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about our collection, use, disclosure, and sale of your personal information and your potential rights with regard to your Personal Information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used in this section have the meaning ascribed to them in the CCPA. We are a “business.” “Personal information” as used in this section has the same meaning as in the CCPA and does not include de-identified information, aggregate consumer information, or publicly available information, as those terms are defined in the CCPA.
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, we may collect the categories of personal information listed above in the section Collection of Your Information.
How We Use Collected Information
We also may use personal information from California Residents for the business or commercial purposes described above in the section How We Use Your Information.
Our Collection, Use, Disclosure, and Sharing of Personal Information
What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information
In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information listed above in the section, Collection of Your Information. We may collect personal information from all or some of the categories of sources listed in the section, How We Collect Your Information. We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section, How We Use Your Information.
Our Disclosure and Sharing of Personal Information
KEOLIS NORTH AMERICA does not sell your personal information. We do not knowingly sell the personal information of California Residents under 16 years old.
In the preceding 12 months, we may have disclosed for a business purpose each of the categories of personal information listed above in, Collection of Your Information, to the following categories of third parties: (i) advertising partners; (ii) analytics providers; (iii) technical service providers; (iv) providers or partners that support our business operations (such as payment services providers; shipping companies; etc.); (v) affiliated entities; (vi) entities who assist with fraud prevention, detection, and mitigation; (vii) providers or partners that support our business operations (such as payment services providers; shipping companies; etc.); (viii) any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets; (ix) judicial courts, regulators, or other government agents purporting to have jurisdiction over us or our affiliates or opposing counsel and parties to litigation; and (x) other third parties as may otherwise be permitted by law.
We may also share your personal information with our service providers such as our IT providers, CRM providers, fraud prevention, detection, and mitigation providers, and other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by, the CCPA.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights with regard to such personal information, including the right to:
- Notice. Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
- Request to Delete. Request that we delete any personal information about you that we have collected or maintained, subject to certain exceptions.
- Request to Know. Request that we provide you with: (i) the categories of personal information we have collected about you; (ii) the categories of sources from which we collected the personal information; (iii) the business or commercial purpose for collecting or selling the personal information; (iv) the categories of third parties with whom we share personal counsel; (v) the specific pieces of personal information we have collected about you; and (vi) the categories of personal information about you we have sold or disclosed for a business purpose.
- Not to Be Discriminated Against. Not be discriminated against because you exercised any of your rights under the CCPA.
- Opt-Out of Sale. Request that we do not sell your personal information (we do not).
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from California Residents where permitted by the CCPA or another law or regulation.
How to Submit a Request Under the CCPA
California Residents may submit Requests to Know through the following methods: (1) emailing us at firstname.lastname@example.org or (2) calling this toll-free telephone number: (857) 267-5365. California residents may submit Requests to Delete through the following methods: (1) emailing us at email@example.com or (2) calling us at (857) 267-5365.
We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, depending on the sensitivity of the information you are requesting and the type of request you are making, your name, and email address. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Request to Know or a Request to Delete on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
We will deliver responses to verifiable consumer requests, free of charge by mail or electronically, at your election. We will try to respond to your Requests to Know or to Delete within forty-five (45) days of receipt of the request. If we require more time, we will try to inform you of our need for an extension. Even with an extension, we will try to provide a response within ninety (90) days of initial receipt of the request. Keep in mind that we are not required to provide information in response to Requests to Know more than twice in a 12-month period. Any response to a Request to Know will only cover the 12-month period preceding the verifiable request.
Additional California Privacy Rights
You have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. Please note, however, that we do not currently disclose any of your personal information to third parties for their direct marketing purposes.
Some web browsers may transmit “do not track” (“DNT”) signals.
Nevada law gives consumers (as defined under Nevada law) the right to request that we not “sell” personal information (including “personal information” as defined under Nevada law) for monetary consideration to certain other parties. To submit such a request, please contact us at firstname.lastname@example.org. However, please note that we do not “sell” your “personal information” as that term is defined under Nevada law.
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