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Privacy Shield Policy



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General Data Protection Regulation (GDPR)
and Privacy Shield Statement

Effective: May 25, 2018


Global Products Inc. and its affiliated entity, Global Products International Inc., (“GPI,” "we," "us," or "our") are committed to protecting the information of our customers, suppliers, vendors, employees, and individuals who browse and use our websites.

Beginning on May 25, 2018, the European Union’s General Data Protection Regulation (“GDPR”) went into effect. The GDPR provides EU residents with greater control over what, how, when and where their personal data is collected, maintained, processed and stored. The GDPR applies to our business to the extent we process personal data of EU residents when marketing and selling our products. We are, however, committed to protecting the privacy of our customers and prospective customers, wherever they are located.

As part of our ongoing effort to maintain the privacy of our Customers’ information and to comply with the GDPR and other applicable regulatory frameworks, we are in the process of voluntarily self-certifying and adhering to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework (“Principles,” “Privacy Shield,” or “Privacy Shield Program”).

We adhere to the GDPR and Privacy Shield principles of Notice, Choice, Accountability of Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability. For purposes of enforcing compliance with the Privacy Shield, GPI is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission and the Department of Transportation. For more information on the Privacy Shield, please visit the U.S. Department of Commerce’s Privacy Shield website. You may view and search the list of companies that have self-certified with the Privacy Shield here:
https://www.privacyshield.gov/list

We adhere to the principles of the Privacy Shield with respect to the information we collect that relates to an identified or identifiable natural person residing in the EU (“Personal Data”).

WHO WE ARE

GPI is a premier provider of promotional items, fundraiser items, logoed apparel and merchandise. We are also a dealer-exclusive designer, manufacturer and distributor of Harley-Davidson® official licensed merchandise. We primarily operate on a business-to-business sales and distribution model.

SCOPE OF STATEMENT

This Statement applies to the processing of customer, prospective customer, vendor and employee Personal Data that we receive in the United States, regardless of where such individuals reside. This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used instead of actual names or identifiers.

INFORMATION WE COLLECT

Our Privacy Policy describes the categories of Personal Data we may receive, collect, store and use in the United States, as well as the purposes for which we use that Personal Data. In summary, we collect data from our customers, prospective customers, vendors, contractors, employees and website users. The categories of Personal Data we collect from customers, prospective customers, vendors, contractors and website users include:

  1. Contact information (name, company name, title, mailing address, telephone, electronic mail address, facsimile address);
  2. Shipping information;
  3. Order information;
  4. Product inquiry information;
  5. Payment information;
  6. Order history;
  7. Communications to and from you;
  8. IP addresses;
  9. Browser information; and
  10. Your activity on our website.

The categories of Personal Data we collect from our employees include:

  1. Human resource administration information;
  2. Employment contract and wage information;
  3. Employment tax and benefit information;
  4. Employee development and training programs;
  5. Recruiting and hiring information;
  6. Employee qualification and performance information;
  7. Termination or resignation information;
  8. Other human resource information

We notify our employees of how their Personal Information will be used and collected.

PURPOSE FOR COLLECTING PERSONAL INFORMATION

We collect, use and process Personal Data for the purposes of:

  1. Providing information about our products, services and events;
  2. Providing products, services and support to our customers;
  3. Maintaining and supporting our products;
  4. Verifying identity (for example, to verify identity prior to accessing online accounts);
  5. Complying with our contractual obligations related to our business, including (without limitation) managing transactions, reporting, invoices, renewals, and other operations related to providing services to our customers;
  6. Communicating with customers, business partners, vendors, agents and contractors about business matters;
  7. Analyzing information to improve our business practices, products and services;
  8. Conducting related tasks for legitimate business purposes;
  9. For other purposes that we disclose to you prior to or at the time of collecting Personal Data;
  10. Compliance with legal requirements, such as governmental reporting, taxes and other requirements (import/export laws); and
  11. As otherwise requested by you or required by law.

We only process Personal Data in ways that are compatible with the purpose for which we collected it, or for purposes you later authorize. Before we use your Personal Data for a purpose that is materially different than the purpose for which we collected it or you later authorized, we will provide you with the opportunity to opt out. We maintain reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete and current.

DATA TRANSFERS TO THIRD PARTIES

We do not disclose your Personal Data to third parties, except under the following circumstances:

  1. We have your permission to make the disclosure;
  2. We are making the disclosure to a third-party agent or vendor who is performing functions on our behalf as described below;
  3. The disclosure is required by law, including to law enforcement or other public authorities; or
  4. The disclosure is reasonably necessary for the establishment of legal claims.

Third Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers that perform functions on our behalf. You can access our current list of sub-processors here. We enter into written agreements with those third-party agents and service providers requiring them to provide the level of protection required by the GDPR if applicable to such third-party agents and service providers, and if not, then compliance with Privacy Shield or the same level of protection that Privacy Shield requires and limiting their use of the Personal Data to the specified services provided on our behalf. We take reasonable and appropriate steps (i) to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and (ii) to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers that perform services on our behalf for their handling of Personal Data that we transfer to them.

DISCLOSURES FOR NATIONAL SECURITY OR LAW ENFORCEMENT.

Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities or to meet national security or law enforcement requirements.

SECURITY

GPI maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction in accordance with the Privacy Shield.

ACCESS RIGHTS

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity.

STAFF AND RESPONSIBILITIES

Everyone who works for or with GPI has some responsibility for ensuring data is collected, stored and handled appropriately. Only employees who need to access or know the Personal Data in order to accomplish their work have access to such Personal Data. Our employees that have access to Personal Data must ensure that it is handled and processed in line with this policy and data protection principles. GPI has designated a Data Protection Officer to oversee its information security policies and procedures, including its compliance with the EU and Swiss Privacy Shield program. The Data Protection Officer shall review and approve any material changes to this policy as necessary.

QUESTIONS AND CONCERNS

Any questions, concerns, or comments regarding this Statement or our use of your Personal Data, please contact us at: privacy@gpii.com

We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within forty-five (45) days of receiving your complaint.

We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within forty-five (45) days of receiving your complaint.

If we cannot resolve an employee data dispute through our internal processes, EU employees may file a claim with the EU Data Protection Authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC)as appropriate. An individual may under certain conditions invoke binding arbitration. Please see the Privacy Shield website for more information on conditions giving rise to binding arbitration.

If we cannot resolve a non-employee data dispute through our internal processes, EU or Swiss persons may file a claim with JAMS arbitration and mediation service. An individual may under certain conditions invoke binding arbitration. Please see the Privacy Shield website for more information on conditions giving rise to binding arbitration.

CHANGES TO THIS STATEMENT

We reserve the right to amend this Statement, as well as our Privacy Policy, from time to time consistent with the Privacy Shield, GDPR and any other applicable laws.



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