This privacy policy (this “Policy”) describes the privacy practices of Delta Modular A.Ş. (referred to throughout this policy as “DM”) [as they relate to this Delta Modular® website (the “Website”) and its associated functionality.
When you come to the Website we log your current internet address (this is usually a temporary address assigned by your internet service provider when you log in), the type of operating system you are using, and the type of browser software used. In addition, we may keep track of what areas of our website you visit. This tracking will occur in the form of a “Cookie” or similar file that will permit tailoring of the website to better match your interests and/or preferences.
This website uses Google Analytics to track website activity and visitor behavior. If you want to opt-out of being tracked by Google Analytics, you may use the Google Analytics Opt-out Browser Add-on. Google Analytics also collects data about visits to the website via the DoubleClick cookie and Floodlight tags. This information is being used to provide demographic and interest data about visitors to the website and to target online display advertisements on third-party websites. Using Google’s Ads Settings, visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.
While we track this information about the technology you are using, we do not identify who you are. You will remain anonymous to our system unless you choose to tell us who you are. For example, when you submit a question via our email submission form or submit your resume for consideration of employment, this information is kept confidential and only disclosed to those who may be able to help answer your question or consider you for employment within the company. We do not disclose your personal information to other companies who intend to sell their products or services to you. For example, we will not sell your name or email address to a direct-marketing company.
General Data Protection Regulation (GDPR) Policy
- CHANGES. DM may change this Policy from time to time in DM’s sole discretion. Accordingly, DM encourages you (“You” or “Your”) to review this Policy periodically. DM shall post an announcement on the Website of any changes to this Policy. The most current version of this Policy shall be linked on the home page of the Website.
This policy was last reviewed and updated 02/15.2019
- INFORMATION COLLECTION, USAGE, AND DISCLOSURE.
DM collects and processes certain information that may personally identify You (“Identifiable Information”).
2.1 COLLECTION OF IDENTIFIABLE INFORMATION
DM collects and processes the following Identifiable Information:
(a) Identifiable Information You give DM. This is information about You that You give DM by filling in forms on the Website or by corresponding with DM by phone, e-mail or otherwise and includes [information You provide when You register to use the Website], [complete the Prospective Supplier Pre-Qualification Questionnaire] or [sign up to use the client portals]. The information You give DM may include Your name, address, e-mail address, user name and password, phone number, Company Name, Job Title/Function, location and details of any comments or feedback You provide to DM.
(b) Identifiable Information DM collects about You. With regard to each of Your visits to the Website, DM may automatically collect the following information:
[(i) technical information, including the Internet protocol (IP) address used to connect Your computer or mobile device to the Internet, MAC addresses, traffic data, location data, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and cookies, which will be collected in accordance with DM’s Cookies Policy https://www.deltamodular.com/privacy-policy
(ii) details of Your visits to the Website and Your preferences and habits when using the Website; DM will use this information to create a profile of You for the purpose of enhancing Your customer experience with DM;
(iii) information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time), Your conduct via the Website and (where relevant) details of the fulfilment of any of Your orders, and any other site activity, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call DM.]
2.2 USAGE OF IDENTIFIABLE INFORMATION
(a) Identifiable Information You give DM. DM will use this information:
- to deal with your enquires and requests;
- to establish and maintain Your registration information;
- to notify You about changes to any of DM’s services;
[to provide You with information about services DM offers that are similar to those that You have already purchased or enquired about, as further detailed in the ‘Marketing’ section below];
- to provide You with customer support; and
- to ensure that content from the Website is presented in the most effective manner for You and Your computer.
(b) Identifiable Information DM collects about You. DM will use this information:
- [to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve the Website to ensure that content is presented in the most effective manner for You and for Your computer
- to allow You to participate in interactive features of the Website, when You choose to do so;
- to measure or understand the effectiveness of marketing to You and others, and to deliver relevant marketing communications about Delta Modular services and offerings to You where permitted; and/or
- to make suggestions and recommendations to You and other users of the Website or DM’s services about goods or services that may interest You or them.]
2.3 USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS.
DM relies on the following conditions to process Your Identifiable Information:
To allow DM to exercise its legitimate interests as a data controller: DM relies on its legitimate interests as a data controller to process the Identifiable Information that You provide to DM as part of Your registration and on contact / feedback forms and to process the Identifiable Information that DM collects from You when You use the Website. It is in DM’s legitimate interests as a business to process the above information in order to provide you with information and updates in relation to DM’s services and ongoing projects, to administer the Website, to ensure that content from the Website is presented to You effectively and securely, and to run promotional features.
To allow DM to perform its contract with You: If You successfully register with DM as a trusted supplier or sub-contractor, DM may enter into a contract with You for the provision of goods and / or services. In order for DM to fulfil DM’s obligations under such contract, DM will need to collect and process Your Identifiable Information.
2.4 RETENTION OF YOUR INFORMATION.
[DM will retain Your Identifiable Information for the period necessary to fulfil the purposes for which the information was collected. After that, DM will delete it.
The retention period may vary depending on the purposes for which the information was collected. Where a specific legal or regulatory requirement applies to Your Identifiable Information, DM will retain it for the period of time specified in such legal or regulatory requirement. In the absence of a specific legal or regulatory requirement, DM will retain Your information for 10 years following the event to which it relates (e.g. the specific project, enquiry, etc). DM may be required to extend the retention period if the information is required due a complaint or because it is required for litigation. Please also note that DM is sometimes legally obliged to retain the information, for example, for tax and accounting purposes.]
2.5 DISCLOSURE OF YOUR INFORMATION.
DM will not share Your Identifiable Information with third parties, save as follows:
with DM’s business partners, product and services suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
with DM’s parents, subsidiaries, and sister companies for the purposes of marketing and only where You have provided Your consent, as described below;
with analytics and search engine providers that assist DM in the improvement and optimization of the Website and other selected third parties;.
DM may also share Identifiable Information with law enforcement / regulatory authorities, other government officials and / or DM’s legal and professional advisors in order to (1) protect or defend the legal rights, property, safety, or security of DM or anyone else, (2) protect against fraud or for risk management purposes, (3) comply with a legal process, legal requirement, judicial proceeding, or court order, (4) investigate a possible crime, such as fraud or identity theft, or (5) as required by law.
DM may also share Identifiable Information in connection with the (actual or potential) sale, purchase, merger, reorganization, liquidation, or dissolution of DM.
DM does not sell any customer or prospect data, but may use such data for measurement or enhancement of customer experience in marketing or sales endeavors. DM does utilize partners in the analysis of web traffic and social media data, but those partners are held to the same standards as DM. Data ownership of web and social interactions occurring on DM sites/platforms are the sole property of DM.
2.6 SECURITY.
DM takes reasonable precautions to protect Identifiable Information and has put in place certain processes and procedures to prevent unauthorized access of Identifiable Information. Unfortunately, there is always a potential risk in sending information through any channels, and DM cannot guarantee that communications between You and DM, including Identifiable Information, shall be free from unauthorized access by third parties. DM shall not be held responsible (i) for any unauthorized access or illegal or unauthorized use of information, including Identifiable Information, or (ii) if Your information, including Identifiable Information, is accessed through unauthorized or improper use of Your account or login information or due to Your failure to secure Your username, password, or customer ID.
2.7 STORAGE OF YOUR INFORMATION.
The data that DM collects from You may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA (for example, in the United States), who work for DM or for one of DM’s suppliers.
When we send Your data to a destination outside the EEA we will make sure suitable safeguards are in place, in accordance with European data protection requirements, to protect the data. In all cases these safeguards will be one of the following:
Sending the data to a country that’s been approved by the European authorities as having a suitably high standard of data protection law.
Putting in place a contract with the recipient containing terms approved by the European authorities as providing a suitable level of protection.
Sending the data to an organization which is a member of a scheme that’s been approved by the European authorities as providing a suitable level of protection. One example is the “Privacy Shield” scheme agreed between the European and US authorities.
More information on these safeguards can be found here: https://ec.europa.eu/info/law/law-topic/data-protection_en.
2.8 MARKETING
DM may use Identifiable Information (including Your email addresses, phone numbers, and unique Device numbers) to send You promotional materials relating to DM’s services that are similar to those that you have already purchased or enquired about. If You have not previously purchased or enquired about such services, DM will not send You promotional materials without first obtaining Your consent to do so.
If You want to stop receiving such promotional materials from DM, then You should follow the applicable unsubscribe or opt-out instructions.
DM’s affiliates or business partners may also use Your personal information to contact You about other goods and services, provided that You have given Your consent.
You may withdraw Your consent to the use of any of Your personal information for marketing purposes, at any time by contacting DM at info@deltamodular.com You will also be given the opportunity in each marketing communication to opt-out of future marketing communications.
- LINKS TO OTHER SITES. The Website may contain links to other websites. Those other websites may not have the same privacy policy as DM, and DM is not responsible for the privacy practices of those other websites. When You visit those other websites, You should read their privacy policies. This Policy applies solely to the Website and the information collected by DM through the Website.
- Your rights
You have certain rights in relation to Your Identifiable Information that is processed by DM. These rights are listed below. These rights are not absolute and apply subject to certain conditions, as set out in applicable data protection laws. Your rights may include:
the right to access personal data held by DM about You;
the right to require DM to rectify any inaccurate personal data held by DM about You;
in certain circumstances, the right to require DM to erase personal data held by DM about You;
in certain circumstances, the right to restrict DM’s processing of personal data held by DM about You;
in certain circumstances, a right to receive personal data which You have provided to DM in a structured, commonly used and machine readable format. You may also have the right to require DM to transfer this personal data to another organization, at Your request;
the right to object to DM’s processing of personal data held by DM about You (including for the purposes of sending marketing materials to You); and
the right to withdraw Your consent, where DM is relying on Your consent to use Your personal data (for example, to provide You with marketing information about DM’s services and products).
To request account maintenance or changes or to update billing information, send Your email request to info@deltamodular.com.