Privacy Statement Effective as of 1/1/2019
SPI Software Solutions, Inc. d.b.a. GreenWave (“GreenWave”, “we”, “our” or “us”) has created this privacy statement (“Statement”) to inform you how GreenWave collects, stores, uses and processes the personal data and information you provide us through this website. Privacy on the GreenWave web site (the “Site”) is of great importance to us. This policy only applies to this site and does not extend to the practices of other Web Sites that we may link to, companies that we do not own or control, or to people that we do not employ or manage. We reserve the right to change this Statement at any time. Any changes will be posted in this Statement or the Cookies Policy and material changes will generally apply only to activities and information collected on a going forward basis. We encourage you to regularly review this Statement and the Cookies Policy to make sure you are aware of any changes and how your information may be used.
By using Site you are accepting the practices described in this Statement (including the Cookies Policy available on this site). If you do not agree to this Statement or the Cookies Policy, please do not use this site. We reserve the right to make changes to this Statement or the Cookies Policy at any time.
Our Contact Information.
Our internet address is located at http://www.GreenWaveCommissions.com.
Our business address is:
SPI Software Solutions, Inc. d.b.a. GreenWave
1451 South Elm Eugene St, Box 85
Greensboro, NC 27406
You may contact us by e-mail at privacy@GreenWaveCommissions.com.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
[Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.]
Before we share your personal data with any third party for their own marketing purposes, we will get your express consent. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at privacy@GreenWaveCommissions.com at any time. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.
When you visit our Site we may collect two types of information: (a) personal information you actively choose to disclose and (b) information about you that is collected automatically by our servers or obtained from third parties in a way not visible to you. (a) Information you actively choose to provide. By choosing to participate in our programs, offers or membership, you must disclose the following information, such as: your email address, name, address, phone number and birth date. During the process of registering on our site, participating in various offers, completing surveys, or sending us emails or correspondence, we collect additional information that you may disclose, including for example mobile telephone number, fax number, payment information (e.g., credit card number and billing address), credit information, health information and personal preferences regarding lifestyle, products or services. (b) Passive information collected automatically by our servers or obtained from third parties. We collect some information about you simply by virtue of you connecting to our web site. Our servers automatically identify your computer by its internet protocol (“IP”) address, a unique string of numbers that is assigned to your computer by your internet service provider. In addition, to participate in our program you must allow cookies to be active on your system. Cookies are a feature of web browser software (Internet Explorer, Netscape Navigator, etc.) that allows web servers to recognize which computer is used to access a web site. Cookies simplify subsequent interactions on our site and streamline your transactions on related web pages. Information collected through cookies may include the date and time of your visits, the site pages you viewed, the time spent at each page, and the web sites you visited just before and just after our site. You can disable the cookie function by following the instructions in the “help” section of your browser. However, doing so will likely make it impossible for our system to properly recognize you when you visit our sites, and consequently may make your participation in our program more difficult or impossible. In addition to the information you provide or that is collected automatically from our system, we may obtain information about you from our marketing partners or other third parties, and we combine that information with the information you actively provide or that is automatically collected by our servers.
The term “Information” is used in this policy to refer to both types of information described above, as well as any Information that you provide to us directly by phone (including any phone number displayed via caller ID), text or SMS message, U.S. mail or through any other written or oral communication with us.
How We Use and Share the Information Collected
We use your Information to administer our business activities, provide customer services such as technical support, distribute information about changes to our site, and send you, and enable others to send you, information about products and services that may be of interest to you and to contact you or use your Information for any other purpose. We send communications to you ourselves, and your Information also is shared with other organizations that may contact you for any purpose by email, phone, text message, U.S. mail or any other means of communication.
OPT-IN NOTICE: By Participating, You Expressly “Opt In” To Receive Information and Grant Us Permission To Share Your Information By signing up for our Program you expressly opt in to receive future information about products and services from us and from a variety of advertisers to whom we may provide your Information. We will share your personal information with third parties, including our advertisers, for any reason we choose, including without limitation for the following purposes: (1) to operate our Program (including the transfer of the information to advertisers or to third parties who maintain on our behalf a list of persons having registered with our Program), (2) to permit advertisers or other third parties to use your Information for any purpose such as contacting you by email, phone, text message, U.S. mail or any other means of communication for any purpose, (3) to confirm you have completed all of the necessary steps to receive your gift, and (4) as we are required to do by law, including to notify the IRS that you received your gift. As a result, we will transfer your Information to third parties whose privacy policies and practices are beyond our control.
In addition, in the event we consider a transaction involving the purchase or sale of our assets or stock, other companies may review our records, including your Information, to make business decisions about the transaction. Likewise, your Information may be transferred to third parties in the event of the sale or acquisition of our company or any of its assets. The parties who perform services for us (credit card processors, merchant banks, our internet service provider, etc.) also may have access to your information in performing their services.
Disclosures of Your Personal Data
We may share your personal data with the parties set out below:
- Other companies in our group who provide services to us.
- Service providers who provide IT and system administration services.
- Professional advisors including lawyers, bankers, auditors, and insurers.
- Government bodies that require us to report processing activities.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Personal Information We Collect
Personal Information refers to information that lets us know the specifics of who you are. Personal Information is requested when you order a service, register for an account and send us feedback. For example, this information might include your name, address (both billing and registered), email address, industry and product details, and credit card or other payment information. Such information may be held on our contacts and administration databases either because of the work we have done with you or are currently engaged in, or because we believe you might be interested in receiving material from us about our business, products, programs and services. This allows us to manage our relationship with you efficiently, improve our site and the services which we offer to you and to target items of interest we may send to you.
Non-personally identifiable information refers to information that is statistical in nature only and that does not, by itself, allow to identify a specific individual or entity, and which depends upon the visiting you do on the site. For example, this information may include the domain from which you access the internet, the date and time you access the site, and the internet address of the website from which you linked directly to the site. This information is used in an aggregate form to make the site more useful and attractive to its users.
Agreements governing your use of special features and password-protected areas.
This site may include special features and password-protected areas. When you sign up to use a special feature or password-protected area, you may be asked to agree to special terms governing your use of the special feature or password-protected area. In such cases, you will be asked to expressly consent to the special terms, for example, by checking a box or clicking on a button marked “I agree.” This type of agreement is known as a “click-through” agreement. If any of the terms of the click-through agreement are different than the terms of this Statement, the terms of the click-through agreement will supplement or amend this Statement, but only with respect to the matters governed by the “click-through agreement.”
Use of Personal Information
Generally, we use the Personal Information we collect through our site:
- To provide the products, information and services you request from us
- For security, credit or fraud prevention purposes or any other legal obligation;
- To contact you with special offers and other information we believe will be of interest to you where you have given us permission to do so.
- Based upon a legitimate interest we have:
- To provide you with effective customer service;
- To provide you with a personalized experience when you use our site;
- To display personalized advertising when you visit our site;
- To contact you with information and notices related to your use of our site;
- To invite you to participate in surveys and provide feedback to us;
- To better understand your needs and interests;
- To improve the content, functionality and usability of our site;
- To improve our products and services;
- To improve our marketing and promotional efforts; and
- For any other purpose identified in an applicable privacy notice or other agreement between GreenWave and you.
What Information We Collect
Communication Data that includes any communication that you send us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data that includes data relating to any purchases or goods and/or services such as your name, title, billing address, shipping address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep your records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services, and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology of the devices you use to access our website. The source of this data is from our analytical tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.
Sharing of Personal Information
Service providers. We share Personal Information with companies and organizations that perform services on our behalf, for example, companies that provide support services to us (such as credit card processing services, data storage services, and web hosting services) or that help us market our products and services (such as third-party e-mail marketing companies). These third parties are required by contract to use the Personal Information we share with them only to perform services on our behalf and to take commercially reasonable measures to protect the confidentiality and security of your Personal Information.
Within GreenWave. We may share the Personal Information we collect through our Site within GreenWave or with other affiliates of GreenWave for cross-marketing and other purposes. If you do not want us to share your Personal Information with another member of the GreenWave family of businesses, you may “opt-out” at any time by sending an email or writing to our data privacy officer – see the contact details on this page.
Business transfers. Your Personal Information may be transferred to a company that has acquired the stock or assets of GreenWave, one of its affiliates, or one of our businesses, for example, as the result of a sale, merger, reorganization or liquidation. If such a transfer occurs, the acquiring company’s use of your Personal Information will still be subject to this policy and the privacy preferences you have expressed to us.
As described in a privacy notice. We reserve the right to disclose your Personal Information as described in any additional privacy notice posted on the web page (or area) where you provide that information. By providing your Personal Information on that web page you will be consenting to the disclosure of your Personal Information as described in that privacy notice.
As described in a click-through agreement. We reserve the right to disclose your Personal Information as described in any click-through agreement to which you have agreed.
Retention of Personal Information
We shall retain Personal Information in accordance with federal, state and local laws, rules and regulations.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or access without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
If, at any time after using the service, you change your mind about sharing your information with third parties, send us a request specifying your new choice. Simply send your request to privacy@GreenWaveCommissions.com.
Technologies We Use
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
GreenWave uses technologies such as cookies and pixels to keep track of your activities on our website, and to serve you more relevant advertisements on third-party websites in order to receive targeted or retargeted ads. A cookie is a small text file that is stored on your device for record-keeping purposes. Cookies are used by nearly all websites and do not harm your system. Session cookies expire when you close your browser. Persistent cookies remain on your device for an extended period of time. We and our third-party partners use session cookies and persistent cookies to make it easier for you to navigate and enhance the experience of our site, and to monitor and evaluate our website’s operation and use.
We use persistent cookies to keep track of your activities when you visit our website in order to help us recognize you and serve relevant advertisements to you when you visit third party websites or online services or websites in their networks. Cookies are either:
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains when you close your web browser. The cookie can be read by the website that created it when you visit that website again. [We use persistent cookies for Google Analytics.]
Cookies can be categorized as follows:
Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.
GreenWave’s policy is that our Advertising Partners only collect information that does not personally or directly identify you via these cookies and we will cease working with partners found violating this policy. You can check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. You may also decline our cookies (including essential cookies) if your browser permits but doing so may interfere with your use of our website.
How You Can Choose to “Opt-out” of Receiving Further Information About Products and Services
We will promptly update our records upon receiving your clear instructions to opt-out, but it may take up to ten (10) business days from our receipt of your request for the change to be fully effective. If you later give us a clear statement that you want to receive emails from us or our advertisers after such date, then that opt-in statement will supersede any earlier opt-out request. If we have already provided your email address or other information to an advertiser or other third party before we receive your opt-out request, we cannot prevent them from sending or continuing to send you information or emails and you will need to contact such third party directly.
How to Correct, Delete or Access Your Information
If you wish to access, delete or correct the information you have provided to us through this site, please contact us through the Contact Us section of our site or through written request sent by U.S. mail to the Customer Service Manager at the address listed above.