Personal Information does not include information that is:
- Lawfully made available from government records.
- Deidentified or aggregate information.
- Otherwise excluded from the scope of the CCPA.
The chart above provides the categories of Personal Information (as defined by the CCPA) which Universal Robots has collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve months since this Privacy Notice was last updated, as well as the categories of sources from which that information was collected, and the categories of third parties with whom we shared Personal Information. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.
Use of Personal Information. Universal Robots may use or disclose the Personal Information that Universal Robots collects for one or more of the following business purposes:
- To fulfill or meet the reason the individual provided the information. For example, if Data Subject’s shares his/her/its name and contact information to ask a question about our products or services, Universal Robots will use that Personal Information to respond to the Data Subject’s inquiry. If an individual provides Personal Information to purchase a product or service, Universal Robots will use that information to process the payment and facilitate delivery. Universal Robots may also save an individual’s information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop products, and services.
- To create, maintain, customize, and secure an account with Universal Robots.
- To provide individuals with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to the recipient.
- To provide an individual with support and to respond to the inquiries.
- To process requests, purchases, transactions, and payments and prevent transactional fraud.
- To deliver content and product and service offerings relevant to an individual’s interests, including targeted offers and ads through Universal Robots website, third-party sites, and via email or text message (with consent, where required by law).
- For auditing related to a current and/or concurrent transaction with a Data Subject.
- To help maintain the safety, security, quality, and integrity of Universal Robots’ products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
- For testing, research, analysis, and product development and demonstration, including to develop and improve Universal Robots’ products, and services.
- To respond to law enforcement requests and as otherwise required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Universal Robots assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Universal Robots about Universal Robots’ website users is among the assets transferred.
- As described, Universal Robots is collecting the Personal Information, as articulated in this Privacy Policy, Privacy Notice or as otherwise set forth in the CCPA.
Universal Robots will not collect additional categories of Personal Information or use the Personal Information that Universal Robots collects for materially different, unrelated, or incompatible purposes without providing notice.
Sharing the Personal Information. Universal Robots may disclose Personal Information to a third party for a business purpose. When Universal Robots discloses Personal Information for a business purpose, Universal Robots enters into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and to not use it for any purpose except performing the contract.
Universal Robots may share Personal Information with the following categories of third parties:
- Related corporations, affiliates, subsidiaries, associated companies, and parent company.
- Service providers.
- Third parties to whom the Data Subject has authorized Universal Robots to disclose his/her/its Persona Information in connection with a product, service or offering.
Disclosures of Personal Information for a Business Purpose. In the preceding twelve (12) months, Universal Robots has disclosed the following categories of Personal Information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records Personal Information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G. Geolocation data
Category I: Professional or employment-related information.
California Privacy Rights. According to the CCPA, California residents may make certain requests to Universal Robots regarding Personal Information, specifically:
- The Right to Access/Know: the specific pieces or categories of the Personal Information, which also maybe disclosed or sold (if any) to the third parties for the business purposes, and categories of such third parties to whom this information was disclosed or sold; and the business or commercial purposes for collecting or selling the Personal Information.
- The Right to Request Deletion: the right to request the deletion of Personal Information, subject to certain exceptions.
- The Right to Correction: the right to request that any inaccuracies in Personal Information be corrected, taking into account the nature of the Personal Information and the purposes of the processing of Personal Information.
- The Right to Opt-Out of Sales or Sharing of Personal Information: the right to direct Universal Robots not to “sell” Personal Information to third parties for monetary or other valuable consideration, or “share” the Personal Information to third parties for cross-context behavioral advertising purposes.
- Right to Limit Use and Disclosure of Sensitive Personal Information: the right to direct Universal Robots to limit the use of the sensitive personal information to certain purposes, including to perform the services or provide the goods or services reasonably.
- The Right to Non-Discrimination: the right not to receive discriminatory treatment for exercising any of the rights described above, with limits to process Personal Information, such as in the case of a deletion request.
- “Shine the Light”: California residents that have an established business relationship with Universal Robots have the right to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). Universal Robots does not share Personal Information with third parties for Universal Robots’ own direct marketing purposes.
Universal Robots may only be able to process the request to the extent it is able to identify individuals in Universal Robots systems. The request should be submitted as mentioned in the section 10 of this Privacy Policy.
Right to Opt-Out of Personal Information Sales or Sharing. Unless a Data Subject has exercised his/her/its right to opt-out of Personal Information sales, Universal Robots may sell Personal Information to third parties for monetary or other valuable consideration. The third parties may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties. These third parties may include business partners, third party advertising networks, social media companies and other third parties.
Do Not Sell or Share Personal Information. In certain circumstances, an individual may be permitted to use an authorized agent to submit requests on their behalf where Universal Robots can verify the authorized agent’s authority to act on their behalf. In order to verify the authorized agent’s authority, Universal Robots generally requires evidence of either (i) a valid power of attorney or (ii) a signed letter containing the name and contact information of the Data Subject of the request, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and location/residency, Universal Robots may still need to separately reach out to the Data Subject to verify the Data Subject’s identity in connection with the request and to confirm that the authorized agent has permission to act on the Data Subject’s behalf.
Appealing Privacy Rights Decisions. Depending on the Data Subject’s location or jurisdiction of residency, the Data Subject may be able to appeal a decision Universal Robots has made in connection with his/her/its privacy rights request. All appeal requests should be submitted in accordance with Section 10 of this Privacy Policy.
Non-Discrimination. Universal Robots will not discriminate against you for exercising any of individual’s CCPA rights. Unless permitted by the CCPA, Universal Robots will not:
- Deny goods or services.
- Charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide a different level or quality of goods or services.
- Suggest that individual may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, Universal Robots may offer certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive that Universal Robots offers will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Contact Information. In case of questions and/or suspected violations of this Privacy Notice, please contact the Data Protection Team at: dataprotection@universal-robots.com
Any request can be exercised free of charge and will be addressed as expeditiously as possible and always within one (1) month or sooner, if required by applicable law.
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Privacy Notice for Residents of Colorado, Connecticut, Utah, and Virginia
In accordance with applicable privacy law, and depending upon the jurisdiction in which the Data Subject resides, the Data Subject may have some or all of the following rights with respect to his/her/its Personal Information:
Right of Access: The Data Subject may have the right to obtain:
- confirmation of whether, and where Universal Robots processes Data Subject’s Personal Information;
- information about the categories of Personal Information Universal Robots is processing, the purposes for which Universal Robots processes the Personal Information and information as to how Universal Robots determines applicable retention periods;
- information about the categories of recipients with whom Universal Robots may share the Personal Information; and
- a copy of the Personal Information Universal Robots holds about the Data Subject.
Right of Portability: The Data Subject may have the right, in certain circumstances, to receive a copy of the Personal Information that Data Subject has provided to Universal Robots in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of the Personal Information to another person.
Right to Rectification or Correction: The Data Subject may have the right to obtain rectification or correction of any inaccurate or incomplete Personal Information which Universal Robots holds about the Data Subject.
Right to Deletion or Erasure: The Data Subject may have the right, in some circumstances, to require Universal Robots to delete erase his/her/its Personal Information.
Right to Restriction: The Data Subject may have the right, in some circumstances, to require Universal Robots to limit the purposes for which Universal Robots processes the Data Subject Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by the Data Subject.
Right to Opt-Out: The Data Subject may have the right to opt-out of certain processing activities. For example, the Data Subject may have the right to opt-out of the use of his/her/its Personal Information for targeted advertising purposes, or to “sell” or “share” his/her/its Personal Information with third parties in certain contexts.
Right to Withdraw Consent: If the Data Subject has provided consent for the processing of his/her/its Personal information, the Data Subject may have the right to withdraw this consent. If the Data Subject withdraws his/her/its consent, this will not affect the lawfulness of Universal Robots’ use of the Personal Information before withdrawal.
Right to Appeal: In the event that Universal Robots declines to take action on a request exercising the rights set forth above, the Data Subject has the right to appeal such decision.
The Data Subject does not need to create an account with Universal Robots in order to exercise its privacy rights. However, before processing the Data Subject’s request, Universal Robots will need to verify Data Subject’s identity and confirm Data Subject’s state if residency. In order to verify Data Subject’s identity, Universal Robots will generally either require the successful authentication of Data Subject’s account, or the matching of sufficient information the Data Subject provides to Universal Robots which maintains in the systems. This process may require Universal Robots to request additional Personal Information from Data Subject, including, but not limited to, email address, and/or date of last transaction with Universal Robots.
Universal Robots will only use Personal Information provided in a privacy rights request to review and comply with the request. If the Data Subjects choose not to provide this information, Universal Robots may only be able to process the request to the extent Universal Robots is able to identify the Data Subject in the system(s). Universal Robots may not process the request if Universal Robots, in good faith, believes that the request is fraudulent. In such instances, Universal Robots will send a notice to the requestor explaining the decision. If Universal Robots is unable to comply with all or a portion of a Data Subject’s request, Universal Robots will explain the reasons for declining to comply with the request.
Opt-Out Rights in Relation to Cookies and Other Tracking Technologies. As is common practice, Universal Robots permits third party advertising networks, social media companies and other third-party businesses to collect and disclose the Personal Information (including preferences, geolocation, commercial information and internet, network and device information) directly from Data Subject’s browser or device through cookies or tracking technologies when the Data Subject visits or interacts with the websites; uses Universal Robots apps; or otherwise engages with Universal Robots. These third parties use this information for the purposes of providing ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting. There third parties may sell that information to other businesses for advertising and other purposes.
To opt out of the sharing of Personal Information with third parties for cross-context behavioral advertising purposes, the Data Subject may submit a request by clicking “Change your consent/Withdraw Your Consent” on the Cookie Policy.
Contact Information. In case of questions and/or suspected violations of this Privacy Notice, please contact the Data Protection Team at: dataprotection@universal-robots.com
Any request can be exercised free of charge and will be addressed as expeditiously as possible and always within one (1) month or sooner, if required by applicable law.