Privacy Policy
Last Updated: March 20, 2024
What Personal Information We Collect
Information You Provide to Us
We collect information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, make a purchase, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us. The types of personal information we may collect, in our legitimate interest and/or as a contractual necessity, include:
- Identifiers such as name, physical and/or email address, telephone number, company name, and job title to comply with your request that we contact you, and for other business purposes (such as sales, marketing, technical service, customer service, and customer experience);
- Financial and payment information for billing purposes;
- Purchase history information as is necessary to improve your customer experience;
- Website areas of interest as is necessary to improve your customer experience;
- User name and password for the security of your user account, to comply with your request that we contact you, and for other business purposes; and
- Information submitted in connection with job applications in order to evaluate and process your application.
Information We Collect Automatically When You Interact with Us
When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:
- Activity Information: We collect information about your activity on our Websites, such as recognizing when you sign in to use our Websites and keeping track of your specified preferences.
- Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and the date of the transaction.
- Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Websites, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
- Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy, www.promega.com/legal/cookie-policy/.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location (at the city, state, or region level) based on your IP address.
How We Use and Retain Your Personal Information
Promega uses your personal information as described above, to process your requests and transactions, in our legitimate interest and/or as a contractual necessity. We also use the information we collect to:
- Provide, maintain, and improve our products and services
- Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;
- Personalize and improve your experience on our Websites;
- Send you technical notices, security alerts, and support and administrative messages;
- Respond to your comments and questions and provide customer service;
- Communicate with you about products, services, and events offered by Promega and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
- Monitor and analyze trends, usage, and activities in connection with our Services;
- Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
- Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Promega and others;
- Debug to identify and repair errors in our Services;
- Comply with our legal and financial obligations; and
- Carry out any other purpose described to you or to which you consent at the time the information was collected.
- We may also de-identify and/or aggregate personal information so that it can no longer identify a specific person and use such information in any manner not prohibited by applicable law.
- Your personal information will be retained as long as is needed for us to comply with our contractual obligations, employment obligations, and other business purposes, including global legal obligations to retain data.
How We Disclose and Transfer Your Personal Information
We disclose personal information in the following circumstances or as otherwise described in this policy:
- We disclose personal information to vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising.
- We disclose personal information to certain third parties such as strategic business partners and affiliates for their own services and marketing purposes.
- We may disclose your personal information to select business partners in our sole discretion, where necessary, to discharge the purposes set forth above or where reasonably required to pursue our legitimate business aims, or to fulfill legal obligations.
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Promega, our users, the public, or others.
- We disclose information submitted by job applicants to applicant screening services in accordance with applicable law or with recruiting service providers for hiring purposes and for general human resources purposes.
- We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is disclosed between and among Promega and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- We disclose personal information with your consent or at your direction.
- We also disclose aggregated or de-identified information that cannot reasonably be used to identify you.
Targeted Advertising and Analytics
We engage others to provide analytics services, serve advertisements, and perform related services across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address and other identifiers, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. Promega may use this information to deliver advertising targeted to your interests on other companies’ sites or mobile apps and to analyze and track data, determine the popularity of certain content, and better understand your online activity. Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under some laws. See California and Other State Privacy Information below to learn how to opt-out of these activities.
How We Respond to Do Not Track Signals
Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Websites are not currently set up to respond to those signals.
Transfer of Information to the United States and Other Countries
Promega is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
Your Choices
Account Information
If you do choose to create an account, you may update and correct certain account information at any time by logging into your account or emailing us at privacyteam@promega.com. If you wish to delete your account, please contact Customer Service but note that we may retain certain information as required by law or for our legitimate business purposes.
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. For more information about cookies and how to disable them, see our Cookie Policy at www.promega.com/legal/cookie-policy/.
Communications Preferences
You may opt out of receiving promotional emails from Promega by following the instructions in those communications or by updating your communication preferences using the following links www.promega.com/communication-preferences-anonymous/ (for users without an account) or www.promega.com/commerce/account/default/communication-preferences (for users with an account). If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Additional Disclosures for Individuals in Europe
If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.
Legal Basis for Processing
When we process your personal data, we will do so in reliance on one or more of the following lawful bases:
- To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
- When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
- To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
- When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.
Data Subject Requests
Subject to certain limitations, individuals within the EEA, United Kingdom, and Switzerland have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at the address listed in the Contact Us section provided below.
Questions or Complaints
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
For individuals in the EEA: edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: ico.org.uk/global/contact-us/
For individuals in Switzerland: www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
California and Other State Privacy Information
California and Other State Notice of Information Collected and/or Disclosed
The California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act (collectively, “CCPA”) and the Shine the Light law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal information. In addition, privacy laws in Virginia, Connecticut, Colorado, Utah, and Iowa provide, or will provide in the future, to consumers residing in those states certain rights with respect to their personal information. If you are a consumer residing in California or Virginia Connecticut, Colorado, Utah, or Iowa, this section applies to you as indicated. This section also applies to California job applicants and those interacting with Promega in their business or commercial capacity in California.
If you are a California employee or former employee, please refer to our Employee Privacy Policy for a description of Promega’s privacy practices in that context.
In the preceding 12 months, we have collected the following categories of personal information:
- Identifiers
- California customer records or similar information in states with applicable privacy laws
- Commercial information
- Internet or electronic network activity information
- Location-related information based on IP address or physical address information
- Professional or employment related information
- Inferences, including information derived from other personal information about you.
- Sensitive personal information, including as part of a job application process, social security number, driver’s license, and race and ethnicity information.
For details about the precise data points we collect and the categories of sources of such collection, please see the What Personal Information We Collect section above. We collect personal information for the business and commercial purposes described in the How We Use and Retain Personal Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
Categories of Personal Information | Categories of Recipients |
---|---|
Identifiers |
|
California customer records or similar information in states with applicable privacy laws |
|
Commercial Information |
|
Internet or other electronic network activity information |
|
Location related information |
|
Professional or employment informationCalifornia customer records or similar information in states with applicable privacy laws |
|
Inferences drawn from personal information |
|
California Sales and Sharing of Personal Information
California law requires that we provide transparency about personal information we “sell” or “share.” “Sale” for the purposes of the CCPA, broadly means scenarios in which Promega has shared personal information with third parties in exchange for valuable consideration, while “sharing” means we have disclosed information to a third party for cross-context behavioral advertising. In addition, the CCPA has been interpreted to deem this “sharing” to also be a form of “sale.” Accordingly, we “sell” personal information for the following commercial purposes: to collaborate with strategic business partners and allow them to offer products and services that might interest you and to advertise our products to you. In addition, in the preceding twelve (12) months, Promega has “sold” or “shared” your personal information to or with third parties for cross-context behavioral advertising, such as targeting of advertising to you based on your personal information obtained from your activity across businesses, websites, apps, and services other than our Services. See the Targeted Advertising and Analytics section above for more information about behavioral advertising. See Privacy Rights below to learn how to opt out of these activities. We do not knowingly sell or share personal information about consumers under the age of 16.
In the preceding 12 months, we have “sold” the following categories of personal information to the following categories of third parties:
Categories of Personal Information | Category of Third Parties |
---|---|
Identifiers | Third party business partners |
California customer records or similar information in states with applicable privacy laws | Third party business partners |
In the preceding 12 months, we have “shared” the following categories of personal information with the following categories of third parties:
Categories of Personal Information | Category of Third Parties |
---|---|
Internet or other electronic network activity information | Advertising and marketing partners |
Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at privacyteam@promega.com.
Information Relevant to Other States
Virginia’s, Connecticut’s, Colorado’s, Utah’s and Iowa’s, privacy law requires that we notify you if we use your information for Targeted Advertising. Targeted Advertising means displaying advertisements to you where the advertisement is selected based on personal information obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests. See Privacy Rights below to learn how to opt-out of these activities.
Privacy Rights
Subject to certain limitations, if you are resident of California or Virginia, Connecticut, Colorado, Utah, or Iowa, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request correction of your personal information, (3) request deletion of your personal information, (4) opt out of any “sales” of your personal information that may be occurring, and (5) not be discriminated against for exercising these rights. If you wish to submit a privacy rights request, please contact Customer Service at 1-800-356-1970 or submit your request through the online Privacy Rights Request Form. Upon receipt, we will verify your request by asking you to provide information related to your recent interactions with us, such as confirming your email address or account information. We will not discriminate against you if you exercise your rights under the applicable privacy laws. You also have the right to opt out of sharing or targeted advertising at any time by clicking on the My Privacy Choices link in the footer of our website. If we need to verify your request, we may do so by asking you to provide information related to your recent interactions with us.
If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us using the address listed in the Contact Us section provided below.
Opt-Out Preference Signals
Some browsers allow you to enable privacy-controls in the browser's settings to automatically signal your opt-out preference to the websites you visit (e.g., Global Privacy Control). We honor Global Privacy Control signals as a valid request to opt-out of the sharing of information linked to your browser. Please be aware, however, that opt-out preference tools are limited to the browser or devise you are using. Also, to maintain your privacy preferences, your browser may save some information in its cookies and cache, and if you clear cookies, you may remove your opt-out preferences so that you may have to opt-out again.
California Notice of Financial Incentive
California’s privacy law requires that we notify you if we provide you a program, benefit, or other offering, related to the collection, deletion, or sale of personal information, which it defines as a “financial incentive.” We offer promotions and incentives to prospective and current Promega consumers. Sometimes, consumers sign up or provide us their personal information (e.g., email address) in order to receive product incentives or participate in promotions. As such, under the CCPA, our product incentives or promotions may be considered financial incentives provided in exchange for the collection and retention of personal information.
We offer these product incentives and promotions to enhance our relationship with you or so you can engage with us while receiving some of these benefits. There is no obligation to opt-in and consumers may opt-out at any time. The details of each program are contained in each such program offering.
The consumer data received in exchange for your participation is dependent on a number of factors, including, for example, whether and to what extent you take advantage of any offerings and whether and to what extent you opt out of any offerings but is roughly equivalent to the value of the product incentive or promotion offered.
Contact Us
Please contact us to learn more about our privacy practices or to change your privacy choices:
Promega Corporation
Privacy Manager
IT Department
Promega Corporation
2800 Woods Hollow Road
Madison, WI 53711 USA
privacyteam@promega.com
Promega UK
Data Protection Officer UK
Promega Corporation
2 Benham Road
Southampton SO16 7QJ
United Kingdom
privacyteamUK@promega.com
Promega GmbH
Data Protection Officer EU
Promega Corporation
Gutenbergring 10
69190 Walldorf
Deutschland
privacyteamEU@promega.com