Last Updated: August 13, 2021
Greenfield Global Inc. and its subsidiaries, and affiliates, including without limitation, Greenfield Global USA Inc., Greenfield Global LFS Ireland Limited, Greenfield Global Quebec Inc., and Greenfield Global Winnebago LLC (“Greenfield” “we,” “us,” or “our”), is committed to protecting your privacy. This Privacy Notice describes how we collect, use, disclose and otherwise process the information we collect about you when you:
- Visit our main website (https://greenfield.com/), its subdomains, and all other websites that Greenfield owns or controls and link to this Notice (collectively, the “Sites”);
- Interact with us online or offline, including by email, telephone, facsimile, social media, and in person at trade shows or other events;
- Apply for a job at Greenfield; or
- Otherwise interact with Greenfield and we refer you to this Privacy Notice.
From time to time, we will supplement this Privacy Notice with additional information about our privacy practices related to a particular activity Greenfield undertakes.
For the purposes of the EU General Data Protection Regulation (“GDPR”), the data controller is Greenfield Global Inc., located at 6985 Financial Drive, Suite 501, Mississauga, Ontario, L5N 0G3, Canada. We provide contact information for Greenfield at the end of this Privacy Notice.
COLLECTION OF PERSONAL INFORMATION
“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, with an individual (e.g., you) or household. If you are located in the European Economic Area (“EEA”) or United Kingdom (“UK”) when we collect information from you, the table also describes our legal basis for processing Personal Information and the term “Personal Information” includes all “personal data” as defined under the GDPR, the UK Data Protection Act of 2018, and other EEA laws.
If you are located in the EEA or UK, we only process your “Sensitive Personal Information” if you give us your explicit consent, the processing is necessary to meet a legal or regulatory obligation, the processing is in connection with the establishment, exercise or defense of legal claims, or is otherwise expressly permitted by the applicable laws. “Sensitive Personal Information” includes special categories of Personal Information (such as information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; genetic data, biometric data, and data concerning health; and information concerning a person’s sex life or sexual orientation) for which the GDPR, the UK Data Protection Act of 2018, or other EEA laws may provide enhanced protections.
We collect the following categories of Personal Information:
- Direct identifiers, such as your name, business address, email address, business phone number, and any personal contact information you voluntarily provide to Greenfield;
- Personal records, such as your payment card information, financial account information, or information about our products or services that you have purchased;
- Employment information, such as your resume, curriculum vitae, employment history, educational history, references, qualifications, and demographic information you voluntarily provide to us in connection with your job application, such as date of birth, sex, race, and ethnicity;
- Online account information, including username and log-in credentials you use to access your user account(s) via the Sites;
- User-generated online content, including information we receive when you submit content via the Sites by completing an online form;
- Site usage information, including information we automatically receive about the devices you use to access the Sites, your IP address, the type of Internet browser you are using to visit the Sites, or the areas of the Sites you visited and the actions you performed on the Sites;
- Limited medical information, to the extent it is relevant to public health and/or your attendance at an in-person event or visit to our facility; and
- Other information you choose to provide, such as when you participate in a survey, promotion, request customer support, or otherwise communicate with us.
We collect this Personal Information from:
- Our direct interactions with you, such as when you inquire about the Sites or our services, provide us your contact details, apply for a job at Greenfield, provide us with information in connection with our services, participate in surveys or questionnaires, subscribe to our newsletters, or in any way engage with us or our personnel;
- Third-party sources, such as when we obtain references and background checks in connection with processing your application for a job with Greenfield; and
- Through social media, such as if you link to social media platforms or use social media plug-ins, we may (depending on your user privacy settings on that social media platform) automatically receive information about you from that social media platform.
HOW WE USE YOUR PERSONAL INFORMATION
The table here describes the purposes for which we collect Personal Information under this Privacy Notice.
Other Uses: We will notify you of any other purposes for which we wish to use your Personal Information that are materially different than those listed above by amending this Privacy Notice in accordance with the section below called “Changes to this Privacy Notice.”
If you are located in the EEA or UK and we need to collect Personal Information by law or under the terms of a contract we have with you, and you fail to provide us with the Personal Information when requested, we may not be able to continue to perform the contract. We will inform you of any mandatory Personal Information we require from you and as to the consequences if you fail to provide it.
HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your Personal Information with the following categories of third parties:
- Within Greenfield, including our various parent companies, subsidiaries and affiliates as needed to operate our organization and for the purposes described above.
- Third-party service providers and vendors whom Greenfield engages to process Personal Information on our behalf for the purposes described above, such as vendors who help Greenfield with website hosting, marketing, payment processing, application processing, and website usage analytics.
- Public and governmental authorities that regulate or have jurisdiction over Greenfield, such as regulatory authorities, law enforcement, public bodies, and judicial bodies.
- Other third parties, as reasonably necessary:
- In relation to a merger, sale, acquisition, divesture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control (whether in whole or in part); and
- To comply with your request.
INTERNATIONAL DATA TRANSFERS
We are committed to complying with this Privacy Notice and applicable data protection laws that apply to our collection and use of your Personal Information. We recognize that the laws in in some countries may not be as protective as the laws of other countries. By providing us with your Personal Information and using our Site, you acknowledge that your Personal Information may be transferred to, and processed in, the United States, Canada, EEA or UK. When transferring your Personal Information to another country where we are located, we confirm that there are adequate safeguards in place to maintain compliance with the protocols herein.
EUROPEAN ECONOMIC AREA DATA SUBJECTS’ RIGHTS
If you are an individual located in the EEA, you have the following rights (subject to certain conditions) with respect to your Personal Information:
- Right of access: You may request details about the Personal Information that we hold. We will confirm whether we are processing your Personal Information and we will disclose supplementary information including the categories of Personal Information, the sources from which it originated, the purpose and legal basis for the processing, the expected retention period, and the safeguards regarding Personal Information transfers to non-EEA countries, subject to the limitations set out in applicable statutes, regulations, and other laws.
- Right of correction: We will comply with your request to edit and update incorrect Personal Information promptly.
- Right to be forgotten: At your request, we will delete your Personal Information if: (i) it is no longer necessary to retain your Personal Information; (ii) you withdraw the consent which formed the basis of your Personal Information processing; (iii) you object to the processing of your Personal Information and there are no overriding legitimate grounds for such processing; (iv) the Personal Information was processed illegally; or (v) the Personal Information must be deleted for us to comply with our legal obligations.
We will inform any third parties we may have shared your Personal Information with of your deletion request.
We will decline your request for deletion if processing of your Personal Information is necessary: (i) to comply with our legal obligations; (ii) in pursuit of a legal action; (iii) to detect and monitor fraud; or (iv) for the performance of a task in the public interest.
- Right to restrict processing of your Personal Information: At your request, we will limit the processing of your Personal Information if: (i) you dispute the accuracy of your Personal Information; (ii) your Personal Information was processed unlawfully and you request a limitation on processing, rather than the deletion of your Personal Information; (iii) we no longer need to process your Personal Information, but you require your Personal Information in connection with a legal claim; or (iv) you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.
- Right to receive notice related to correction, deletion, and limitation on processing: To the extent it is practicable, we will notify you of any correction, deletion, and/or limitation on processing of your Personal Information.
- Right to data portability: At your request, we will provide you free of charge with your Personal Information in a structured, commonly used and machine readable format, if: (i) you provided us with Personal Information; (ii) the processing of your Personal Information is based on your consent or required for the performance of a contract; or (iii) the processing is carried out by automated means.
- Right to object: If we process your Personal Information based upon Greenfield’s legitimate interest, then you have the right to object to this processing activity.
- Right to withdraw consent: You have the right to withdraw any consent you may have previously given us at any time. If you withdraw your consent, this will not affect the lawfulness of our collecting, using and sharing of your Personal Information up to the point in time that you withdraw your consent. Even if you withdraw your consent, we may still use your information that has been fully anonymized and does not personally identify you.
If you wish to contact us in connection with the exercise of your rights listed above, please contact us at: Greenfield Global Ireland LFS Ltd. c/o Greenfield Global Inc. – Legal Department, 6985 Financial Drive, Suite 501, Mississauga, Ontario, L5N 0G3, Canada, Email: firstname.lastname@example.org.
We will respond to your written request without unreasonable delay and in accordance with any deadlines imposed by law. If we decline your request, we will tell you why, subject to legal restrictions. Unless we notify you at the time of your request, we will not charge you any fee in connection with the exercise of your rights.
FILING COMPLAINT WITH SUPERVISORY AUTHORITY
If you are not satisfied with our response, you have the right to complain to or seek advice from a supervisory authority and/or bring a claim against us in any court of competent jurisdiction. For example, you may use the following information to contact the Irish Data Protection Commission:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2, D02 RD28 Ireland
Phone: +353 578 684 800
+353 761 104 800
YOUR CALIFORNIA PRIVACY RIGHTS
California residents have the privacy rights listed below. The rights listed below under the California Consumer Privacy Act (“CCPA”) and Shine the Light are not the same. To exercise your rights as a California resident, you will need to follow the directions below that are specific to each law.
Collection, Use, and Disclosure of Your Personal Information in the Past 12 Months. The CCPA requires that we make certain disclosures about our general collection, use and disclosure of California consumer Personal Information over the past 12 months. Accordingly, in the past 12 months:
- We collected the categories of Personal Information from the sources detailed in “Collection of Personal Information” and for the purposes described in “How We Use Your Personal Information” above.
- We did not sell any Personal Information as we understand this term under the CCPA and its implementing regulations.
- We have disclosed the categories of Personal Information listed in “Collection of Personal Information” to third parties. The categories of third parties with whom we have shared this Personal Information in the past 12 months are detailed above in “How We Share Your Personal Information.”
Request to Know. You have the right to request to know the following information about our practices over the past 12 months: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which we collected the Personal Information about you; (iii) the categories of third parties with which we share Personal Information, (iv) the categories of Personal Information we sold or disclosed about you and for each category, the categories of third parties to which we sold or disclosed that particular category of Personal Information; (v) our business or commercial purpose for collecting or selling your Personal Information; and (vi) the specific pieces of Personal Information we collected about you.
You may exercise your right to request to know twice a year, free of charge. If we are unable to fulfill your request to know, we will let you know the reason why. Please note, in response to a request to know, we are prohibited from disclosing your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions or answers, and unique biometric data generated from measurements or technical analysis of human characteristics.
Request to Delete. You have the right to request that we delete the Personal Information that we have collected from you. We may deny your request under certain circumstances, such as if we need to retain your Personal Information to comply with our legal obligations or if retaining the information is necessary to complete a transaction for which your Personal Information was collected. If we deny your request to delete, we will let you know the reason why.
Right to Non-Discrimination. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our Websites.
To make a request to know or a request to delete, please contact us using the information provided under “Contact Greenfield” below.
We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify that you are the individual about whom we collected Personal Information. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we will not require you to create an account with us but we may request additional information about you so that we can verify your identity. We will only use the Personal Information you provide to verify your identity and to process your request, unless you initially provided the information for another purpose.
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. You may also make a verifiable consumer request on behalf of your minor child.
CALIFORNIA SHINE THE LIGHT
California residents may also request information from us once per calendar year about any Personal Information shared with third parties for the third party’s own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To make such a request, please reach us at the contact information listed below. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below.
SECURITY AND RETENTION OF PERSONAL INFORMATION
The security of your information is important to us. We have implemented reasonable technical, physical and administrative security measures intended to protect your Personal Information from unauthorized access, disclosure, alteration or destruction. Please keep in mind, however, that no data transmitted over the Internet is 100% secure and any information disclosed online can potentially be collected and used by persons other than the intended recipient. Accordingly, we cannot guarantee or warrant the security of any information you transmit using the Site.
We keep your Personal Information for as long as needed to fulfill the particular purpose for which it was collected. We may also retain your records if legally required or to fulfill our legitimate interests, including, but not limited to, defending Greenfield against a legal claim.
To opt-out of receiving marketing from us, please click the unsubscribe link at the bottom of a marketing email or let us know by reaching us at the contact information below. Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.
ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS
The Sites may contain links to websites not affiliated with Greenfield. Your use of an external website or any informational content found on an external website is subject to and governed by the privacy policies, terms, and conditions of that website. Further, we are not responsible for the privacy practices of any external websites.
DO NOT TRACK
Certain web browsers and other devices you may use to access the Sites may permit you to submit your preference that you do not wish to be “tracked” online. We do not currently commit to responding to “do not track” requests, in part, because no common industry standard for “do not track” has been adopted by industry groups, technology companies, or regulators.
If you have questions or concerns regarding the way in which we use your Personal Information, please email us at email@example.com.
CHANGES TO THE PRIVACY NOTICE
We may modify or update our privacy practices from time to time. If we make any material changes to the ways in which we process your Personal Information, then we will notify you of these changes by updating this Privacy Notice. The updated Privacy Notice will supersede all previous versions. Your continued use of the Sites and our products and services after the Effective Date of the updated Privacy Notice constitutes your acceptance of the updated Privacy Notice.