Global Privacy Policy

In this Privacy Policy, the words “our,” “us,” “we,” and “FineLine” refer to FineLine Technologies, Inc., and its affiliates, which are leading providers of data and RFID solutions to more than 350 global retailers and consumer brands and 60,000 manufacturers worldwide.

We collect and use information about our website visitors, our online products and services, and our mobile application in order to manage your relationship with FineLine and to better serve you.

The term “Sites” or “FineLine Sites” refers to our websites, mobile app, and any other online platforms or applications managed or controlled by FineLine that link to this Privacy Policy.

The information we collect from you depends on the nature of your relationship with us or your interaction with FineLine’s Sites.

Personal Data. For the purposes of this Privacy Policy, “Personal Data” means information from which you could be identified, directly or indirectly, and may include contact and business information (such as name, title, email address, account information, payment information), information from third parties, social media data, IP addresses, device IDs, and any other unique identifying information. For purposes
of South Africa’s Protection of Personal Information Act (POPIA), “Personal Data” also includes information about an individual juristic person.

Information you provide us:

• We collect information about you through mechanisms of our sites such as contact or order forms.
• We also collect information when you contact us directly through other means of communication such as email.
• When you use our mobile application, you can choose to submit photos to us through it

Information we collect automatically:

• Log data. As with most internet technology services, our servers automatically collect information when you access or use our Sites and record it in log files. This log data may include your IP address, usage data, browser type, the date and time of Site access, and language preferences cookies (if enabled).
• Device Information.
  FineLine collects data about devices accessing the Sites, including the type
  of device, device settings, application IDs, and unique identifiers.
• Location Information.
• We receive data from you and other third parties that helps us to track an
  approximate device location. You can also choose to enable geolocation within our mobile application.
• Cookies and Similar Technologies. Please see our Cookie Policy for information about how we collect and use cookies and other
  similar technologies.
  

We use the information collected for the following purposes:

• To provide you services and to process your order on FineLine’s
  transactional websites
• To improve the operation of the Sites
• To engage in research and development of FineLine’s product offerings, or
  to conduct market research
• To conduct ordinary business operations such as sales, marketing, support,
  education and training
• To engage in corporate reporting and management
• To maintain a safe and trusted environment for FineLine employees, customers,
  site visitors and members of the public
• To conduct other similar uses pertaining to the FineLine Sites

Sharing with FineLine Affiliates:
We may share your information with our FineLine entities worldwide for the purposes described in this Privacy Policy. FineLine affiliates are subject to this Privacy Policy, our internal privacy policies, and local data protection requirements.

Sharing with third party service providers:
We retain third party service providers to manage or support certain aspects of our business. These third-party service providers may be located globally and may provide services to us such as website hosting, data analysis, advertising and marketing services, data hosting, live-chat and helpdesk services, providing information technology infrastructure, customer service, email delivery, credit card
processing, auditing and other similar services. Our third-party service providers are contractually bound to safeguard any Personal Data they receive from us and they are prohibited from using such Personal Data for any purpose other than to perform the services as instructed by FineLine.

Engaging in corporate transactions:
Circumstances may arise where we may buy or sell assets or businesses as part of a sale, merger or change in control of FineLine. In such transactions, we may disclose or transfer your information, in accordance with this Privacy Policy, to prospective or actual purchasers.

Complying with law / protecting legal rights:
We may be required to disclose your information to comply with applicable laws (including laws outside of your country of residence), regulations, court orders, government and law enforcement requests, including national security or other law enforcement requirements. Additionally, if we reasonably believe that it is necessary or appropriate, we reserve the right to use or disclose your information to allow us to pursue available claims or remedies and protect our legal rights, property or the safety of our employees, users or others, to the extent allowed by applicable law. This includes exchanging information with companies and organizations for the purposes of fraud detection.

FineLine relies on the following legal bases for processing Personal Data:

• Order processing: We will capture your Personal Data to provide you goods and services.
  
• Consent (where you have given consent): We process certain Personal Data based on the consent you provided or notice that we provided you when you submitted your information. Where we rely on your consent, you have the right to withdraw or decline your consent at any time by contacting us.
  
• Contract (where processing is necessary for the performance of a contract with you, e.g., to process your order or deliver the FineLine product or services you or your organization have purchased).
  
• Legitimate interests of FineLine or any third parties: Legitimate interests include enabling us to conduct internal business services, such as audits, mergers and acquisitions, reporting, and improving our products and services. Personal Data will only be processed on these grounds when doing so does not outweigh your interests or fundamental rights.
  
• Compliance with laws (where we are required to process information to comply with applicable laws) : If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as the possible consequences if you do not provide your information).

We have implemented and maintain technical, administrative and physical security measures designed to protect your information from unauthorized access, disclosure, misuse, alteration, accidental loss or destruction.

However, no website or internet transmission is completely secure. While we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur, and we cannot warrant the security of any information that you provide to us. You are responsible for securing and maintaining the privacy of any password(s) and account registration information uses with FineLine and verifying that the information we maintain about you is accurate and
current. We are not responsible for protecting any information that we share with a third party based on an account connection that you have authorized.

FineLine is a global company and your information is stored on regional servers depending on your location and the locations of the servers of the companies we hire to provide services to us based on contractual requirements.

We will retain your Personal Data for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, or unless the information is deleted pursuant to the exercise of your rights. We may also retain cached or archived copies of information provided to us.

FineLine is a global company with business processes, management structures and technical systems that cross national borders. This means that your Personal Data may be transferred internally to FineLine Affiliates and externally to third parties (including partners and service providers) across international borders for the purposes described in this Privacy Policy.

INDIVIDUALS IN THE EEA AND UK: Sometimes we may need to transfer information to countries in which applicable laws may not offer the same level of data protection as the laws of your home country.
When we transfer Personal Data from individuals in the EEA or UK to countries that have not received an adequacy finding under Article 45 of the GDPR/UK GDPR, we rely on the safeguards set forth in Article 46 of the GDPR/UK GDPR or derogations for specific situations set forth in Article 49 of the GDPR/UK GDPR. When relying on a cross-border transfer mechanism under Article 49, we only collect and transfer your Personal Data to third countries: (i) with your explicit consent; (ii) to execute perform
a contract with you or a contract with another party for your benefit; or (iii) to establish, exercise, or defend legal claims. You may request of copy of any applicable Article 46 agreements by contacting us as detailed in the “Contact Us” section.

INDIVIDUALS IN SOUTH AFRICA: When we transfer information from individuals in South Africa to foreign countries, we either (i) enter into binding agreements that upholds principles for reasonable processing of the information that are substantially similar to the conditions for the lawful processing of Personal Data and include provisions substantially similar to section 72 of POPIA concerning the further
transfer of personal information from the recipient to third parties in other countries, (ii) conduct such transfers with your consent, or (iii) transfer data in order to conclude or perform a contract in your interest.

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. Please be aware that, if you do not allow us to collect some types of Personal Data, we may not be able to deliver certain products and services to you, and may not be able to take account of your interests and preferences.

All users have the following choices about our collection of Personal Data.

• Account settings. You may update your profile, your account and any related information at any time to ensure that information is up to date.
• Devices and browsers. Some of our mobile services use your device’s location information. You can adjust the setting of your mobile device at any time to control whether your device communicates location information.
• Communications from FineLine. We may use your information to communicate with you by email, including by sending you transactional or marketing emails. FineLine enables you to opt out of marketing communications by clicking “unsubscribe” in the footer of any email you receive from us.
• Cookies. Some web browsers (including mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features or functionalities available through our services. Please go to
  our Cookie Policy to learn more on how you can manage your cookie preferences or opt out of cookies and other website data collection tools.

Additionally, depending on your geographic region, you may have other rights under GDPR, UK GDPR, POPIA, PIPEDA, Hong Kong’s Personal Data Privacy Ordinance, and other applicable privacy laws. These rights may include:

• Data Access: You may request access to the Personal Data we hold about you.
• Data Portability: You may request an export of certain types of Personal Data
• Deletion: You may request to have your Personal Data deleted or erased.
• Correcting inaccurate or incomplete information: You can request that we correct errors in the data we maintain about you.
• Withdrawing consent: If the processing of your Personal Data is based on your consent, you may withdraw your consent at any time.
• Objecting to or restricting use of Personal Data: You can ask us to stop using all or some of your Personal Data or to limit our use of it.
• Individuals in the EEA, UK, and South Africa: You have the right to lodge a complaint with a supervisory authority (EEA) or with the Commissioner (UK) or with the Information Regulator (South Africa at inforeg@justice.gov.za) if you believe we have processed your information in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may have the opportunity to address your concern.

To exercise any of these requests, please contact us as set forth below.
California Residents – For information about California resident privacy rights,
click here.

FineLine does not knowingly collect information from minors as defined by applicable law. If we discover we have received any Personal Data from a minor in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone who is a minor, please contact us so that we can delete their information.

The license to use our mobile application is between you and FineLine only, and not with Apple. FineLine grants you a non-transferable license to use the App only on iOS devices that are owned or operated by you and in accordance with the Apple Media Services Terms and Conditions. Apple is in no way obliged to provide any maintenance or support services for the mobile application. If the mobile application does not conform to an applicable warranty, you are entitled to inform Apple, so that Apple may reimburse you the purchase price of the mobile application, if applicable. Apple does not assume any other warranty obligation for the mobile application. Apple is not responsible for addressing any claims brought against Apple by you or a third party in connection with your use and/or possession of the App. This limitation includes: (a) product liability claims; (b) claims on the basis that the App fails to conform to applicable legal or regulatory requirements; and (c) consumer protection, privacy, or similar laws and regulations. In the event of a third-party claim that the mobile application infringes a third party’s intellectual property rights, FineLine, not Apple will be responsible for the investigation, settlement, defense, and discharge of any such claim. You may not use the mobile application if you are located in a
country that is subject to a U.S. government embargo or that has been designated by the U.S. Government as a “terrorist supporting” country. You may not use the mobile application if you are listed on any U.S. Government list of prohibited or restricted parties. Apple does not assume any responsibility for the investigation, defense, settlement, or discharge of any claims alleging infringement of third party
intellectual property rights. Apple, and Apple’s subsidiaries, are third party beneficiaries of these end user terms, and that, upon your acceptance of the terms and conditions, Apple will have the right (and will be deemed to have accepted the right) to enforce these terms against you as a third party beneficiary of them.

From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements. We will notify you of any changes in accordance with applicable law.

If you believe your Personal Data has been used in a way that is not consistent with this Privacy Policy or your specified preferences, or if you have further questions related to this Privacy Policy, we encourage you to please contact us by emailing: privacy@finelinetech.com.