1WorldSync Privacy Policy

Last Updated: September 17, 2019

1.  Introduction

This 1WorldSync Data Privacy Policy (this “Privacy Policy”) describes the information collection practices that 1WorldSync Holdings, Inc. and its subsidiary, namely 1WorldSync Inc., 300 Charles Ewing Boulevard, Ewing, NJ 08628, and (“1WorldSync”, “we”, “us”, or “our”, if not explicitly referring to one company) follow when handling Personal Data (defined below). This Privacy Policy applies to the collection and processing of Personal Data through our websites, user applications and online stores (collectively, the “Sites”) as well as through other means (e.g., offline during a business relationship or via telephone calls). 

Personal Data of 1WorldSync employees, job applicants, contractors and any other such individuals is not subject to this Privacy Policy, but will be covered under separate 1WorldSync policies and procedures. 

“Personal Data” means any information relating to an identified or identifiable natural person (a “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data does not include information that is anonymized. Personal Data also does not include corporate information that relates to an organization but not to an individual, such as a corporate name, corporate address or general corporate phone number. However, if it is combined with your Personal Data in a manner that reasonably allows it to be associated with your identity, or is otherwise considered Personal Data under applicable law, it will be treated as Personal Data under this Privacy Policy. 

2.  Information We Collect From or About You 

a. User Requests and Business Interactions

We collect Personal Data that you provide to us through our Sites, through business requests via telephone, fax or email and in connection with other business dealings we may have with you. This includes basic contact information about you, such as your name, title, address, phone number, fax number and email address that you provide to us in this course. It may also include information on the products or services you have shown interest in or purchased from us. Additionally, it may also include information on the company you are working for, which is then treated as Personal Data to the extent associated with your identity. If you use a credit card to purchase a product or service from us, we also may collect information necessary to process the credit card transaction, such as the credit card type, number and expiration date. 

b. Use of Our Websites

Website Usage Information. In addition to Personal Data that you choose to submit to us, whenever you visit or interact with our Sites, we may collect or store information regarding your use of our Sites for the purpose of the technical provision of the website (“Usage Information”). This information is typically anonymous information. However, if it is combined with your Personal Data in a manner that reasonably allows it to be associated with your identity, or is otherwise considered Personal Data under applicable law, it will be treated as Personal Data under this Privacy Policy. 

Usage Information is automatically collected for each visit of our Sites and stored in our server log files. This information refers to the computer system of the requesting computer. The following information is or may be collected thereby: 

  • IP-address 
  • Browser type / -version (e.g., Firefox 59.0.2 (64 Bit)); 
  • Browser language (e.g., German); 
  • Operating system (e.g., Windows 10); 
  • Internal resolution of the browser window; 
  • Screen resolution; 
  • Javascript activation; 
  • Java on / off; 
  • Cookies on / off; 
  • Color depth; and 
  • Time of access. 

c.  Online Store- Not intended for use by EU residents

When potential customers visit the 1WorldSync Online Store, those customers are asked to register with 1WorldSync Inc. by creating a profile or, for repeat customers, updating their customer profile. During registration, 1WorldSync requests company name, mailing address and contact information (which includes name, email and phone number) for the registrant, as well as a technical contact and a billing contact. 1WorldSync will use the technical contact information for communications from 1WorldSync and customer’s trading partners in relation to products and services the customer has requested from 1WorldSync. When a separate billing contact is provided, 1WorldSync will use that billing contact for billing purposes only. 

If a customer adds 1WorldSync products or services to its cart in the Online Store, but does not complete the action, it is considered an abandoned cart. 1WorldSync records the following information for each abandoned cart – customer name, company, date of abandoned cart, product name, quantity, cost, email and company’s primary recipient. This information is then relayed to the sales department of 1WorldSync, Inc., where the appropriate sales representative follows up to determine if the customer requires additional assistance to complete the order.

d.  Information We Receive From Third Parties

We may receive Personal Data about you from third parties, such as business partners or sales referral partners who recommend or suggest that we contact you for business purposes. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address. It may also include information on the products or services you have shown interest in or may be interested in purchasing from us, as well as information on other companies or individuals with whom you do business. To the extent we have received your consent, we may also obtain Personal Data about you from third parties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction. 

Generally, you are not obligated to provide us with your Personal Data. However, if you do not provide this data, we may not be able to make our website available to you, answer your questions and enter into a contract with you.

3.  Purposes for Which We Use Your Information

a. Business Use

We use your Personal Data primarily to facilitate our ongoing and proposed business dealings with you (“Business Use”). This includes to: (1) process business transactions with us that you initiate; (2) establish and maintain customer accounts so that we may provide products or services of ours requested by you or your company; (3) register you as a user of these products or services so that you may access them through our Sites or otherwise; (4) communicate with you about updates, maintenance, outages or other technical matters concerning these products or services; (5) communicate with you about data requests of other participants in our services, with whom you synchronize your data through our products or services; (6) provide you with training regarding usage of these products or services; (7) notify you about changes to any of the policies and procedures for use of these products or services; (8) verify the accuracy of account and technical contact information we have on file for you and your company in relation to these products or services; (9) respond to questions or inquiries that you or your company may have about our products or services, and (10) send you invoices and facilitate payments for our products and services that you have used. 

b. Legal Compliance

We also may use your Personal Data as required for us to comply with laws and regulations relating to the products or services that we provide in any of the jurisdictions in which we or our affiliated companies operate, including the United States.

c. Complaints and Improvement of Our Products or Services

We also may use your Personal Data, such as information you provide in connection with complaints or requests, internally within 1WorldSync to help us improve our products or services, or to develop new products or services in order to answer your complaints and comply with your requests. We may also follow up with you to see, if our proposal or solution solved your complaint or request successfully, or otherwise addresses your needs. 

d. Marketing Purposes

We may use your Personal Data for purposes relating to the marketing of our products and services, or those of our business partners (“Marketing Purposes”). This includes to: (1) send you newsletters, press releases, event announcements and other similar communications regarding the products or services that we offer; (2) market or promote our products or services to you, including by offering you trial or limited access to certain of our products or services; (3) solicit input from you regarding improvement of our products or services; and (4) other purposes that we disclose to you at the time we obtain your consent. Upon your consent, we may further use your Personal Data to (1) inform you of third-party offerings that we think you or your company may be interested in which relate to our products or services; and (2) send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our products or services. 

e. Referrals

From time to time, we may receive Personal Data about you from third parties, such as business partners or sales referral partners, who recommend or suggest that we contact you for business purposes. We receive such Personal Data because you have consented towards the third party that they might share your Personal Data with us. If we use that information based on your consent to contact you, it will only be to see if you are interested in our products or services, or those of our business partners. We will not use this information for other purposes without your consent. In addition, if you inform us that you are not interested in these products or services, we will stop using the information to contact you. 

f. Data Integrity

You are responsible for the accuracy of all Personal Data that you provide to us. We will use reasonable efforts to maintain the accuracy and integrity of your Personal Data, and to update that information as appropriate upon your request. We will take reasonable steps to ensure that the Personal Data we collect from you is relevant to its intended use, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorized by you. 

We process and retain your Personal Data for the duration of our business relationship. This may not only be for the time necessary to answer any user request, but may also include the initiation of a contract (pre-contractual legal relationship) and the performance of a contract, including any post-contractual obligations. 

4.  With Whom We May Share Your Information

a. Within 1WorldSync

1WorldSync transacts business internationally. Accordingly, from time-to-time and subject to the provisions of this Privacy Policy governing YOUR RIGHTS AND CHOICES (see below), we may share your Personal Data and Usage Information within 1WorldSync (i.e., between and among 1WorldSync and its subsidiaries). Such information may be used by each 1WorldSync entity for internal business and operational purposes, as well as for purposes consistent with the purpose for which the information was originally collected or subsequently authorized by you. 

b. With Third Parties Outside of 1WorldSync

We share your Personal Data with third parties outside of 1WorldSync only insofar as this is legally permitted or prescribed and we limit the transfer of your Personal Data to what is necessary for the respective purpose. We share your Personal Data with the following categories of recipients: (1) payment service providers and banks, if applicable, during payment processing; (2) external service providers for sending invoices by post or email; (3) logistics service providers; and (4) collection companies and legal advisors in asserting our claims. We may also share your Personal Data with other third parties for purposes disclosed to you and as subsequently authorized by you through your consent. The recipients act independently with your Personal Data, which we have transmitted to them. We will not share your Personal Data with third parties outside of 1WorldSync for their marketing purposes without your consent as required by applicable law.

c. Service Providers

We may from time to time employ service providers to perform services on our behalf, such as: (1) hosting our Sites; (2) designing and/or operating certain features available through our Sites; (3) sending emails and other communications relating to our products or services; (4) fulfilling and processing orders for our products or services; (5) assisting with promotions and conferences relating to our products or services, or those of our business partners; or (6) performing other administrative services for us. We may provide these service providers with access to your Personal Data in order for them to complete a requested transaction or otherwise perform services for us or for you on our behalf. Prior to allowing our service providers to access your Personal Data, we will enter into appropriate agreements with them to ensure that they handle and process the information in accordance with this Privacy Policy and applicable law as instructed by us. 

d. Promotions

We may offer various promotions (“Promotions”) through the Sites or elsewhere that may require registration with your Personal Data. If you choose to enter or otherwise participate in a Promotion, your Personal Data may be disclosed to third parties in connection with administration of the Promotion, such as in connection with winner selection, prize fulfillment and as otherwise required by law. By entering into a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. These rules will be displayed to you during the registration process, and you will be asked for your consent to the respective data processing at that time. 

e. Business Transfers

1WorldSync or any part of its business, including our Sites, may be sold at some point in the future. Should this occur, your Personal Data may be transferred to a subsequent owner, co- owner or operator of the business unit or Site. We also may disclose and transfer your Personal Data in connection with a corporate merger, consolidation, restructuring, the sale of stock or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

f. Legal Protections and Law Enforcement 

Like everyone who participates in economic activities, we are also subject to a large number of legal obligations. These are primarily statutory requirements (such as, but not limited to, commercial and tax laws), but also, where applicable, regulatory or other official requirements. The purposes of processing may include identity and age verification, fraud and money laundering prevention, the prevention, combating and investigation of terrorist financing and offences endangering assets, the fulfilment of fiscal control and reporting obligations and the archiving of data for the purposes of data protection and data security as well as verification by tax and other authorities. Furthermore, the disclosure of Personal Data within the framework of official/judicial measures may become necessary for the purposes of taking evidence, prosecution or the enforcement of civil law claims. We may access, use, preserve, transfer and disclose to third parties your Personal Data to: (1) satisfy any applicable law, regulation, subpoena, governmental request, or legal process if in our good faith opinion such is required or permitted by law; (2) protect and/or defend this Privacy Policy or other policies or terms of use applicable to our Sites, including investigations of potential violations thereof; (3) protect the safety, rights, property or security of 1WorldSync or any third party; and/or (4) detect, prevent or otherwise address fraud, security issues or breaches, or technical issues. This may include allowing third parties, such as copyright owners, Internet service providers, wireless service providers and/or law enforcement agencies, to access and use your Usage Information in order to identify you. We may take any of these steps without notice to you to the extent permitted by law. 

g. Site Hosting

Our Sites and the servers on which they are hosted are operated in various countries around the world in which we conduct our business. Thus, your Personal Data associated with our Sites may be transferred to and/or processed in a country other than that from which it was collected. The data protection laws in those countries may differ from those of the country in which you are located. 

In addition to the above circumstances, we may share your Personal Data with other parties as directed by you or subject to your consent. We may also share and otherwise process aggregated information or de-identified information that does not identify you individually with other parties. For example, we may share aggregated statistics about pages viewed on our Sites, demographic information and sales, and other shopping information with third parties to enrich your visitor experience. 

5. The Legal Basis of Processing

Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including: (a) as necessary to perform a transaction (such as in order to provide the products and services you requested); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to substantiate tax liability); (c) consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies); and (d) necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of our Sites). 

6. Your Rights and Choices

Where required by applicable law, you have the right to obtain confirmation that we maintain certain Personal Data relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us as described below. In particular, you have the right to object to our use of Personal Data for direct marketing and in certain other situations at any time. 

If you receive a marketing communication from us by email, you may also opt out of receiving future email marketing communications by following the opt-out instructions provided in that email. Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in. Please note that we reserve the right to send you certain communications relating to transactions you initiate, your customer account, your use of our Sites, or other business matters, and that these communications may be unaffected if you choose to opt-out from marketing communications. 

Cookies and similar tracking technologies, such as beacons, scripts, and tags, are small bits of code, usually stored on a user’s computer hard drive or device, which enable a website to “personalize” itself for each user by remembering information about the user’s visit to the website. 

Our Sites use cookies to store your preferences, display content based upon what you view to personalize your visit, analyze trends, administer the site, track users’ movements around the site, serve targeted advertising and gather demographic information about our user base as a whole. More detailed information about our use of cookies and how to opt-out of advertising and certain other cookies, is provided below. 

Cookies. A cookie is a data file placed on your device when you visit our Sites. We use cookies to facilitate the use and navigation of our Sites and to remember you and your preferences in case you revisit our Sites in the future. Information collected relates to technical information, such as your browser, a timestamp and a unique identifier. Almost all browsers allow blocking of cookies in their entirety, removal of existing cookies or warning to prevent the placing of a cookie. You can find more information on this functionality in the documentation or in the help file of your browser. Please note that blocking of cookies might impede your use of our Sites. 

We also work with third party advertising companies who place their own cookies or similar technology on your browser or device when you visit our Sites and other websites to serve customized advertisements to you as you browse the Internet. As noted above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered. As an additional step, these advertising companies may participate in one of the following self-regulatory programs for online behavioral advertising, with corresponding user opt-outs: 

Please note that even if you reject such technology, you may continue to receive advertisements, but the advertisements will not be tailored to your browsing activities and interests. 

Marketo. We use Marketo to create landing pages and forms. Marketo allows us to track the activity and form entry of anonymous visitors on our website and landing pages by the use of tracking cookies. This serves the purpose of addressing these visitors adequately. Data collected by Marketo includes an IP address and a user’s affiliation (suspected based on the IP address) to: company, city, state, metropolitan region, country of origin. We have ensured that an IP anonymization is activated and your IP address is therefore processed only anonymized. 

In accordance with our routine record keeping and applicable law, we may delete certain records that contain your Personal Data. We are under no obligation to store such information indefinitely, and we disclaim any liability arising out of, or related to, the destruction of that information. 

7. Automated Decision Making

We do not use automated decision making or profiling (an automated analysis of your personal circumstances). 

8. Information Security

We will take reasonable precautions to protect your Personal Data in our possession from loss, misuse, and unauthorized access, disclosure, alteration or destruction. We will make reasonable efforts to keep your Personal Data reliable for its intended use, accurate, current and complete. As necessary, we will take additional precautions regarding the security of particularly sensitive information, such as credit card information. While we strive to secure your Personal Data, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control. 

9. Links to Other Websites and Applications

The Sites may contain various links to other third-party websites or applications, which may provide additional information, goods, services and/or promotions. These third-party websites are owned and operated independently of 1WorldSync, and may have their own separate privacy and data collection practices. We are not responsible for the privacy practices of any third party. Therefore, you should review their privacy policies and practices prior to interacting with their websites or applications, using any of their tools, or sharing any of your Personal Data with them.

10. Community Forums

Our Sites may offer message boards, chat rooms, blogs and other public areas (“Community Forums”) where you can interact with our other customers, post images, data, requests, questions, comments, suggestions or other content, including your Personal Data (“User Submissions”). To participate in Community Forums, you may be asked to select a user name and password and/or provide us with your email address, and to agree to the terms of participation for those Community Forums. We use this information to identify you and to contact you, if needed, for the provision of those Community Forums. Your password and your email address will not be visible to other users or shared with third parties. You should be aware that any User Submissions you post to a Community Forum, as well as your user name, may be viewed by other members of that forum. If you choose to voluntarily post User Submissions to a Community Forum, the protections of this Privacy Policy will not apply to any Personal Data included in those User Submissions. Think carefully before you post and use caution before disclosing any Personal Data in a Community Forum. We are not responsible for the accuracy, use or misuse of any User Submission that you disclose or receive through a Community Forum. We might also delete User Submissions without further notice if they include harmful or inappropriate content (e.g., pornographic material, content encouraging vandalism, crime, terrorism, racism, violence or cruelty), or infringe any third party’s rights or applicable law. 

11. Children

The Sites are intended for business use, and we do not knowingly collect any Personal Data from children younger than the age of eighteen (18), or otherwise as prohibited by applicable law. 

12. EU Data Subjects and Privacy Shield

1WorldSync, Inc. in the United States participates in the EU-U.S. Privacy Shield Framework (the “Framework”). 1WorldSync Inc.’s participation in the Framework applies to personal data received in the United States from the European Union or European Economic Area (“EU”) about former, current, or prospective corporate customer contacts (collectively, “EU Personal Data”). We are committed to subjecting such EU Personal Data to the Framework, including its Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the Framework, visit the U.S. Department of Commerce’s Privacy Shield List. 

Former, current, or prospective corporate customer contacts have the right to exercise choice (opt-out) from our use of their EU Personal Data for direct marketing purposes. To exercise this right, please follow the instructions in any direct marketing message you may have received (e.g., click the provided opt-out link in the email message or send us an email or postal mail request to opt-out in accordance the instructions provided in the direct marketing message). We do not otherwise use or disclose EU Personal Data in a manner that is subject to choice requirements under the Framework because we do not provide EU Personal Data to third parties other than those acting as our agent to perform tasks on our behalf and we do not receive Sensitive Personal Data (i.e., Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health or sex life or sexual orientation) under the Framework. 

Please contact us as specified below if you have any questions, need access to your EU Personal Data, or otherwise need assistance. We remain responsible for our collection, use and disclosure of EU Personal Data in accordance with the Framework. We also are responsible for third party agents that are processing such data on our behalf, unless we prove that we are not responsible for the event giving rise to the damage. In certain situations, we may be required to disclose EU Personal Data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements. 

If you are a European Data Subject with an unresolved complaint or dispute arising under the requirements of the Framework, we agree to refer your complaint under the Framework to an independent dispute resolution mechanism. That independent dispute resolution mechanism is the International Centre for Dispute Resolution, operated by the American Arbitration Association. For more information and to file a complaint, you may contact the International Centre for Dispute Resolution by phone at +1.212.484.4181, or by visiting the website. We are also subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Framework. In addition, under certain conditions, more fully described on the Privacy Shield website, EU data subjects may invoke binding arbitration for non-monetary issues when other dispute resolution procedures have been exhausted. 

Please contact us at legal@1worldsync.com if you have any questions, wish to exercise your rights of access, or seek other assistance as described above. 

13. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time, without prior notice to you, to the extent permitted by applicable law and the principles of the Framework. We will notify the changes that we make to this Privacy Policy by posting the revised Privacy Policy on the Sites, and such changes will be effective immediately unless otherwise stated.

14. Contact Us

If you have questions or comments regarding this Privacy Policy or our privacy practices, please contact us at: 

1WorldSync, Inc. 300 Charles Ewing Boulevard Ewing, NJ 08628 U.S.A.

Telephone: +1 866 280 4013 within the U.S.

Telephone: +1 937-610-4223 outside the U.S.

Email: legal@1worldsync.com 

You may also have the right to lodge a complaint with the relevant data protection supervisory authority.