ПОЛИТИКА КОНФИДЕНЦИАЛЬНОСТИ

Last Updated: February 2023

1. INTRODUCTION

Purpose

The purpose of this Privacy Policy is to describe how Peli Products, S.L.U. and Peli BioThermal, Ltd. ("Peli"), as a data controller, collects, uses and shares information about you (including Personal Data). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us as described at the end of this Policy.

Our Privacy Policy explains

Information We Collect and Why We Collect It
How We Use and Share Your Information
Access to Your Information and Choices
Security of Your Information
Consent To Processing Personal Data in other Countries
Changes to Our Privacy Policy
Questions and How Contact Us

Scope; Third Party Sites

This Privacy Policy applies to Personal Data we collect

• at and through peil.com, pelibiothermal.com, and certain Peli affiliated sites accessible through or that may redirect you to our website (collectively referred to herein as the “Site”);
• In email, text, and other electronic message between Peli and yourself;
• When you interact with us directly; or
• When you provide us your Personal Data directly.

Some of our affiliated sites owned by Peli are governed by their own separate privacy policies, such as Pelican Products.

Our Site may also contain links to third party websites that are not owned or controlled by Peli. For example, consumers in certain countries and jurisdictions may be directed to websites owned and operated by independent Peli dealers. Please be aware that we are not responsible for the privacy practices of websites not owned or operated by Peli.

Please review the privacy policy available on each site you visit for the privacy practices with respect to that site.

Terms of Use

Please note that your use of our Site and this Privacy Policy are subject to our Terms of Use.

2. INFORMATION WE COLLECT AND WHY WE COLLECT IT

Information You Provide To Us

We collect several types of information(“Personal Data”). This includes:

• Personal Identification Information, including name, postal address, e-mail address, telephone number, credit or other payment card information, any other identifier by which you may be contacted online or offline;
• Site usage information, including traffic data, location data, logs, referring/exit pages, date and time of your visit to our Site, error information, clickstream data, and other communication data and the resources that you access and use on the Site; and
• Information about your internet connection, the equipment you use to access our Site and usage details.

You can provide information to us directly, such as when you purchase products from us, fill out forms on our Site or digital forms, contact us, voluntarily respond to surveys we provide from time to time, or create an account with us.

The Personal Data we collect from you is required to enter into a contract with Peli, for Peli to perform under the contract, to provide you with our products and services, to respond to questions or inquiries from you, or provide you with requested information about us, our product, or our services. If you refuse to provide such Personal Data or, where applicable, withdraw your consent to our processing of your Personal Data, then we may not be able to enter into the contract or fulfill our obligations to you under it. You must notify Peli of any modification to the Personal Data provided and you will be solely liable for the veracity and accuracy of the Personal Data you provide to us.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site or transmitted to other users of the Site or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

When you purchase products from us, you may provide us information like your payment card or bank account information, shipping address or delivery instructions. We use this information in connection with, for example, you order, including processing, fulfilling, and delivering your order, and to provide support in connection with the products you purchase.

We generally do not collect and do not process any special categories of Personal Data as defined by the EU GDPR.

Information We Collect through Automatic Data Collection Technologies

As you navigate through our Site and otherwise interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns.

The information we collect automatically may include Personal Data, or we may maintain the collected information or associate it with Personal Data we collect in other ways or receive from third parties. We collect Personal Data and information about the computers, devices, or browsers that are used to access our Site and interact with us, as well as your Internet activity as you use and interact with our Site. The information we collect may include unique identifiers, browser type and settings, device type and settings, operating system, mobile network information (including carrier name and phone number), and application version number. We also collect information about the interaction of your apps, browsers, and devices with our services, including IP address, device type, crash reports, system activity, wireless carrier name (when you use a wireless or mobile device), and the date, time, and referrer URL of your request.

We may collect information about your activity on our Site, Internet, network, and other online activity information, such as browsing history, search history, and information regarding your interaction with our Site and other websites. We use various technologies to collect and store location information, including cookies, pixels or pixel tags, local storage, such as browser web storage or application data caches, databases, session replay, and server logs.

We may collect information about your location when you use our Site, which helps us provide our Site Services, features and functionality. Your location can be determined with varying degrees of accuracy by:

• GPS
• IP address
• Sensor data from your device
• Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices

The types of location data we collect depends, in part, on your device and account settings. For example, you can turn your mobile device’s location on or off using your device’s settings.

In some circumstances, Peli also collects information about you from publicly accessible sources. We may collect information about you from trusted partners, such as marketing partners that provide us with information about our potential customers, and security partners that provide us with information to protect against fraud and abuse of our Site.

This data collection helps us to improve our Site and to deliver a better and more personalized service by enabling us to:

• better provide our products and services to you, including the operation of our Site;
• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Site according to your individual interests;
• develop and improve our Site, our products, and our services; and
• recognize you when you return to our Site.

Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy.

No Information from Children Under Age 16

If you are under the age of 16, please do not attempt to register with us at this Site or provide any Personal Data about yourself to us. By registering at this Site or providing any Personal Data, you represent and warrant that you are 16 or older being solely responsible for this declaration. If we learn that we have collected Personal Data from a child under the age of 16, we will promptly delete that information. If you believe we might have any information from a child under the age of 16, please Contact Us online or call us at (800) 473-5422.

3. HOW WE USE AND SHARE YOUR INFORMATION

Lawful Basis for Processing your Personal Data

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below), including:

• Consent. By using our Site or otherwise providing us your Personal Data, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use the Site or provide us with your Personal Data;
• Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your interests and rights and freedoms, and we do not process your Personal Data if your interests or rights and freedoms outweigh our legitimate interests. Our legitimate interests include: facilitating communication between Peli and you; improving our Site; safeguarding our IT infrastructure and intellectual property; detecting and preventing fraud and other crimes; promoting and marketing our business; and developing our products and services.
• To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our products and services; and
• As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to certain legal processes, such as lawfully-issued subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims. To the extent that your Personal Data is not relevant to any of these legal processes, we will use our best efforts to remove or otherwise protect your Personal Data from disclosure in response to these requests.

To Provide Products, Services, and Information

As described above, we collect information from you so that we can provide you with information and support that you request from us. We use your Personal Data to contact you about your requests and to facilitate our response.

If you have previously authorized us to do so, we may send you information about our products, services, and new offerings. You can opt-out of receiving marketing and promotional materials or communications from Peli by sending us an email at info@peli.com saying "Please remove," or using the opt-out or unsubscribe feature contained at the bottom of these e-mails.

We may provide information to third party service providers that help us process orders, and to fulfill and deliver products and services that you purchase from us. This includes the company that manages and operates our online store, and our authorized dealers and distributors who help us provide, fulfill, ship, and process orders and product purchases. We may use third parties to help host our Site and provide other technology support, send out email updates, provide marketing and advertising services, remove repetitive information from our user lists, and process payments. All these service providers will have access to relevant Personal Data in order to provide these services. When this occurs, we implement reasonable contractual and technical protections to limit their use of that Personal Data to providing the service. We use demographic information to better understand our customers and improve our products and services.

We may also share your Personal Data with distributors in our network so that they may contact you with information about our products, which we believe may be of interest to you.

We will store your Personal Data as long as is necessary to provide you the products, services, or information that you have requested, for as long as we have a lawful basis to do so, or for as long as we are required by law. After the expiration of such a period, though, we will delete your Personal Data from our systems or anonymize your Personal Data in a way that prevents attribution indefinitely.

After you close your account, we may retain your Personal Data:

• for as long as necessary to comply with any legal requirement;
• on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
• for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
• for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

Advertising

With your consent, we may process your browsing and shopping patterns to show you advertisements for Peli or our advertising partners that are relevant to your interests.

Peli does not use your Personal Data with any automated decision-making process, including profiling. However, we use cookies and other information to provide relevant interest-based advertising to you, including the use of automatic identifiers in emails that direct you to information, products, and services that may be of interest to you. Interest-based advertisements are advertisements presented to you based on your browsing behavior in order to provide you with advertisements more tailored to your interests. These interest-based advertisements may be presented to you while you are browsing our Site or third-party sites not owned by Peli. We belong to ad networks or use marketing companies that may use your browsing history across participating websites to show you interest-based advertisements on those websites. You can learn more about your choices and how we use Personal Data in Cookies, Flash Cookies, and Web Beacons by visiting our Cookie Policy.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Site may then be inaccessible or not function properly. If you choose to opt out, you will continue to see advertisements on our Site but they will not be based on how you browse and shop.

We do not respond to “do not track” signals or similar mechanisms to indicate that you do not wish us to collect information about your online activity or receive interest-based advertisements. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org).

Your Consent

In addition to sharing for reasons as described elsewhere in this Policy, we will share Personal Data with companies, organizations, or individuals outside of the Peli when we have your specific and prior consent to do so; in any other way we may describe when you provide the information; and to fulfill any other purpose for which you provide it. You may freely revoke such consent at any time by contacting us below.

Legal Requests or Requirements and to Prevent Harm

We will share Personal Data with third party companies, organizations, or individuals outside of Peli if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process, or enforceable governmental request.
• Enforce applicable Terms of Use, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security, or technical issues.
• Protect against harm to the rights, property, or safety of Peli, our users, customers, or the public as required or permitted by law.

By submitting your Personal Data or continuing your use of the Site, you consent to these disclosures to the extent that your consent is necessary under the applicable regulation.

Transfer in the Event of Sale or Change of Control

If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your Personal Data to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently. By submitting your Personal Data and accepting this Privacy Policy, you agree to this transfer. Following such transfer, you may contact the entity to which we transferred your Personal Data with any enquiries concerning the processing of that data.

4. ACCESS TO YOUR INFORMATION AND CHOICES

We do not control the collection and use of your Personal Data collected by third parties described above in Section 3 (How We Use and Share your Information). These organizations are under contractual obligations which limit their use of your Personal Data to providing the services to us and to maintaining this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data:

• Access and Update. You can access and review your Personal Data by contacting Peli using the information provided below. You may also notify us through the information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
• Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of your Personal Data if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
• Portability. To the extent the Personal Data you provide Peli is processed based either on your consent or the performance of a contract between you and Peli, and that we process through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in a structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
• Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by contacting us using the information below. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
• Right to be Forgotten. You have the right to request that we delete your Personal Data under certain circumstances. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in our archival or disaster recovery systems. These will be retained for the periods set forth in our disaster recovery policies. If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Site users.
• Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country in which you live, the country in which you work, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve your concerns.

You may exercise your rights set forth above by contacting Peli using the information provided below. Any such request must include the following data: full name, address for correspondence, and photocopy of national identification or passport. In the case of representation by a third party, this must be proved by means of an authenticated document.

5. SECURITY OF YOUR INFORMATION

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

In order to help secure your Personal Data, access to your Personal Data is password-protected, and certain Personal Data (such as a payment information) is protected by encryption when it is exchanged between your web browser and our Site. To protect any data you store on our servers, we also regularly audit our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the Internet is not a completely secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organisational safeguards. The safety and security of your Personal Data also depends on you. It is your responsibility to protect the security of your login information. Please note that e-mails, User Contributions, and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

6. CONSENT TO PROCESSING PERSONAL DATA IN OTHER COUNTRIES

Peli's Site are operated and managed on servers located and operated within the European Economic Area (EEA) in countries that provide adequate level of data protection. If you are a resident of the European Economic Area (“EEA”), in order to provide our Site, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country in which you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.

Your Personal Data is transferred by Peli to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Site, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside the country where you reside or are located. To ensure your Personal Data is treated in accordance with this Privacy Policy when we transfer it to a third party, Peli uses Data Protection Agreements between Peli and all other recipients of your Personal Data that include, where applicable, Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”).

7. CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review upon request.

8. QUESTIONS AND HOW CONTACT US

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, please find our details below:

Peli Products, SLU.
Provença, 388, planta 7
Barcelona, Spain. 08025
Tel: (+34) 93 467 4999
Tel 2: (+34) 93 487 7393
info@peli.com