Your privacy is important to CompuCom Systems, Inc. and its subsidiaries and affiliates ("CompuCom").
EU-US and Swiss-US Privacy Shield Frameworks
CompuCom Systems, Inc. is subject to the jurisdiction, and investigatory and enforcement powers of the Federal Trade Commission (“FTC”) Personal information we collect under the Privacy Shield Frameworks includes contact information such as your name, address, telephone number, and email address, as well as billing and transaction information such as your credit card number, order details, and user IDs and passwords for accessing our websites. We collect and use this personal information to: assist you in connection with a transaction or order; communicate with you about products and services; provide service and support; update you on services and benefits; provide personalized promotional offers; select content to be communicated to you; and/or prevent and detect fraud or other malicious activity. Any credit card information we collect is used solely for processing payments and is not used for any other purpose.
We may disclose certain types of your personal information to third-party service providers who provide services directly to us for our own purposes, and we may disclose registration information (name and contact information) to our business partners for use in connection with a joint marketing campaign with that business partner. For additional information on disclosures, generally, please see the section titled “Sharing of Your Personal Information,” below.
We may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
In cases of onward transfer to third parties of data of EU and/or Swiss individuals received pursuant to the Privacy Shield, CompuCom Systems, Inc. is potentially liable.
If your personal information is subject to the Privacy Shield Principles you have the right to access that information (as well as information about its processing, recipients of that information, and categories of information involved), and to correct, amend, or delete information that is inaccurate or processed in violation of the Principles (except where the burden or expense of providing access would be disproportionate to the risks to your privacy for the case in question, or where the rights of persons other than yourself would be violated).
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to email@example.com or use the contact information provided in the next paragraph. If requested to remove data, we will respond within a reasonable timeframe.
CompuCom Systems, Inc.
c/o Paul Gagnier, CompuCom Legal Department
3800 Arco Corporate Drive, Suite 550
Charlotte NC 28273
CompuCom Systems, Inc. has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Preserving the Security of Your Personal Information
CompuCom charges its employees with protecting your personal information while it is in our custody. Collectively, we at CompuCom take extensive precautions to protect your personal information. We have put in place a combination of physical, administrative, and technical controls to safeguard the information we collect from you.
Collection of Your Personal Information
The types of personal information you provide us on our web pages may include contact information such as your name, address, telephone number, and email address, as well as billing and transaction information such as your credit card number, order details, and user IDs and passwords for accessing our sites. If you prefer not to provide contact information via our websites, please call us at 972-856-3600 to request information about our services.
Use of Your Personal Information
CompuCom may use your personal information in one or more of the following ways:
- to assist you in connection with a transaction or order;
- to communicate with you about products and services;
- to provide service and support;
- to update you on services and benefits;
- to provide personalized promotional offers;
- to select content to be communicated to you; or
- to prevent and detect fraud or other malicious activity.
Any credit card information we collect is used solely for processing payments and is not used for any other purpose.
In addition to the information you provide directly to CompuCom, we may collect information about your visit to a CompuCom website through such methods as automated data collection tools (e.g., cookies, which are small text files that a website saves on your computer or mobile device when you visit the website) and embedded web links.
The cookies we use may be session cookies (those that only last during your session on the site) or persistent cookies (those that remain on your device for a pre-defined period of time). These cookies, which are set by third parties acting on our behalf, include those placed by GoogleAnalytics, HubSpot, Inc., Monster.com, Spiceworks Inc., and CRM Targeting. Information collected via these cookies may be accessible by the third party setting the cookie.
The cookies are used to enhance website functionality, deliver content faster based on your geographic location, analyze website uses, remember your preferences and customize your online experience, enhance our marketing and advertising efforts, and for analytical purposes. Information collected via cookies may be matched with other information we have about you in order to enhance our outreach efforts to you.
These tools can collect certain standard information that your browser sends to our website such as your browser type, language, access times. You may be able to set your browser to alert you when cookies are being sent. You can also control and/or delete cookies as you wish – for details, see http://aboutcookies.org. You may also exercise options regarding Google Analytics cookies at http://tools.google.com/dlpage/gaoptout. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit our websites and some features of our websites may not function properly.
We may also use web beacons in promotional email messages to determine whether the message was opened and acted on. We may use this information concerning email response to develop future promotions you may enjoy.
We do not collect personally identifiable information about your online activities over time and across third-party websites or online services other than as described herein. We do not permit our third-party service providers to collect information from this website for other websites other than as described herein. This website does not respond to web-browser “do-not-track” or other similar mechanisms.
Use of Email Addresses
We use email addresses provided to us in the following ways:
- Return email: We use email addresses to answer the email we receive.
- Promotional email: From time to time, we may send promotional emails to our existing clients and to others that have demonstrated an interest in our products and services. We offer you the option not to receive such promotional email messages (by emailing us at firstname.lastname@example.org).
- Email addresses obtained from events: To market our products and services, we use email addresses obtained through business reply cards and forms at events (for example, seminars). If you receive an email from us following such an event, we may provide a "message reply" option for you to elect not to receive future email messages related to our product and service promotions (or you may always email us at email@example.com).
We will obtain express or implied consent from you before contacting you whenever we are required to do so by law (such as the Canadian “anti-spam” law).
If you set up an account for use on our website, we will collect information from you as necessary to support your use of the account and to process transactions you make using the account. In addition, when you create an account, you will be required to create a username and password. It is your responsibility to maintain the confidentiality and security of your account username and password. You are responsible for all activity occurring in or through your account using your username and password.
Access To, and Accuracy of, Your Personal Information
CompuCom provides individuals with reasonable access to their own personal information that they provide to us. To protect your privacy, we may take reasonable steps to verify your identity before granting access to your data.
CompuCom strives to maintain accurate records of personal information. To help maintain this accuracy, we use a variety of technologies and management techniques. If your personal information changes or you would like to review the personal information we may have on file, please email us with the new information or your review request at firstname.lastname@example.org.
Sharing of Your Personal Information
Other than sharing within the CompuCom family of companies, CompuCom will not disclose an individual's personal information to third parties, except when one or more of the following conditions is true:
- CompuCom has the individual's permission to make the disclosure;
- the disclosure is reasonably related to the sale or disposition of all or part of our business;
- the disclosure is to persons or entities providing services on CompuCom's or the individual's behalf; or
- the disclosure is to a business partner and consists of registration information (name and contact information) submitted in connection with a joint marketing campaign with that business partner.
CompuCom may share your information to protect the safety, property, or other rights of CompuCom, its affiliates, customers, or employees, or when we believe that the law requires it. We will share your information:
- when release is required by law or regulation, or is otherwise required to be produced to a government agency (for example, in response to a subpoena);
- when the disclosure is reasonably necessary for the establishment or CompuCom’s defense of legal claims; or
- upon discovery of potential fraudulent activity or other deceptive practices, to a governmental agency that we believe should be notified.
Note that CompuCom may share aggregate information (not personally identifiable) with our business partners. For example, CompuCom may inform a business partner that a certain number of individuals visited a certain area on our website or that a certain number filled out a registration form.
Links to Other Sites
We may also provide social media features that enable you to share information with social networks and to interact with CompuCom on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites. Actions you take in connection with social media features may be reflected in a manner visible to others; for example, if you “Like” us on Facebook, others may be able to see that you have done so.
No Use by Children Under the Age of 18
We are committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information of minors under the age of 18, including the Children’s Online Privacy Protection Act of 1998, and California’s statute titled “Privacy Rights for California Minors in the Digital World.”
Individuals under the age of 18 are not permitted to use CompuCom sites without the supervision of a parent or legal guardian. We do not knowingly collect or solicit personal information from children under the age of 18 or knowingly allow such persons to register for an online account or to place orders or provide personal information through CompuCom sites. If we learn that someone under the age of 18 has provided any personal information through at CompuCom site, we will remove and delete that information as soon as reasonably possible.
If you are a parent or guardian who believes that your minor under the age of 18 has submitted personal information or other information to us without your consent, please contact email@example.com. Once we verify that you are the parent or legal guardian, we will cooperate with you to discuss what, if any, personal information we may have about your child and how that information may have been shared or used.
Your California Privacy Rights
Under California’s “Shine the Light” law, California residents who provide personal information in connection with purchasing products or services from us may make a request concerning personal information, if any, that we have shared with other businesses for their own direct marketing purposes. Such a request may be made by sending an email message to firstname.lastname@example.org with “Request for California Privacy Information” in the subject line of the message. In response to such a request, we will provide information as required by the California law for the previous calendar year concerning such other businesses and the categories of personal information, if any, that we have shared with them.
Changes to This Policy
CompuCom Systems, Inc.
c/o CompuCom Legal Department
8106 Calvin Hall Road
Fort Mill, SC 29707
Effective September 21, 2017