PRIVACY POLICY

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Such changes to this Privacy Policy will be posted on the Website(s) and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of the Website(s) or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change in a materially new way, we will provide you notice by a prominent post on our website and/or email before using your Personal Information in the new way.

Contact Us

If you have any questions about our Services or this Privacy Policy, please email us at CustomerCare@pens.com. You may also send us a letter to the following address:

Personal Information

We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Identifiers (e.g., name, IP address, mailing address, email address, phone number, fax number, login credentials)
• Demographic Information (e.g., gender, marital status)
• Commercial Information (e.g., checking account number, other payment information, shopping and purchase history)
• Internet or Other Electronic Network Activity (e.g., browsing history, search history, other information regarding your use of our Website(s) or Services that can be associated with you)
• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information (e.g., call recordings, chat transcripts, testimonials)
• Professional or Employment-Related Information (e.g., occupation, employer)
• Inferences drawn from the above categories of Personal Information that relate to your characteristics and preferences

The type of Personal Information we collect about you may vary based on how you use the Website(s) and/or Services and your relationship with us.

Usage Data and Site Activity

We automatically collect anonymous or aggregated information in connection with the actions you take on the Website(s) and in connection with using the Services (“Usage Data”). For example, each time you use the Website(s), we automatically collect the type of web browser you use, your operating system, your Internet Service Provider, the pages you view, and the time and duration of your visits to the Website(s). We may use and disclose Usage Date for any purpose without restriction.

Communication Recordings

We may record calls and retain the content of text messages, chat transcripts, or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

Voluntary Disclosure

We may ask you to provide us with Personal Information when you register with the Website(s), make a purchase, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Website(s) or Services or we may not be able to fulfill your purchase.

Surveys

From time to time we, or service providers retained by us, may request Personal Information from you via surveys. Participation in these surveys is completely voluntary and you have a choice whether to disclose Personal Information. The requested information typically includes contact information (such as name and address) and product usage and preferences.

Third-Party Data Sources

We collect Personal Information from third-party data sources such as the United Parcel Service and data brokerage companies. This Personal Information may be appended to Personal Information we have already collected from or about you to create a “profile” for you.

Third-Party Data Sources

We collect Personal Information from third-party data sources such as Canada Post and data brokerage companies. This Personal Information may be appended to Personal Information we have already collected from or about you.

Cookies

We use cookies (a small text file placed on your computer to identify your computer and browser) to improve the experience of the Website(s) and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Cookies are set by us as well as by our third-party partners. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Website(s) or Services may not work if you delete or disable all cookies.

We use the following types of cookies:

• Functional Cookies: Functional cookies are used to enable site functionalities and keep track of you or your information as you move from page to page within the Website(s). For example, session cookies stored on your browser allow your online shopping cart to function properly and resumes your session when you return to the website.
• Attribution Cookies: Attribution cookies reside on your system and allow us, and our Service Providers, and customize your experience if you leave and later return to the Website(s). For example, attribution cookies may allow us to remember your demographic information & preferences.
• Advertising Cookies: Advertising cookies help us market our products to you and others.
• Analytics Cookies: Analytics cookies help us understand how our Website(s) is working and who is visiting our Website(s).

Certain cookies in the categories above may allow us or third parties to identify you when you visit our Website(s) or develop profiles related to your interests and engagement with us and/or the third party. You may opt out of all cookies except Functional Cookies by setting your Cookie Preferences in the Privacy Notification Banner.

Online Behavioral Advertising

We may work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of the Website(s) or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to better understand individual users. We try to retain and analyze data in a way that anonymizes it, but it is possible that we may collect or use Personal Information as part of our online behavioral advertising activities. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Website(s), the Services, or on third-party websites. You can visit the Network Advertising Initiative website at www.networkadvertising.org, which offers information about Internet advertising companies and how to opt out of participating Advertisers’ information collection. You can also opt out of our use of advertising cookies by setting your Cookie Preferences in the Privacy Notification Banner to disable advertising and attribution cookies.

Tracking Pixels and Clear GIFs

We employ software technology that enables us to track certain aspects of a user's visit to the Website(s). This technology helps us better manage content on the Website(s) by informing us what content is effective, how consumers engage with the Website(s), and how consumers arrive at and/or depart from the Website(s). The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs." Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user's session, such as IP addresses and the type of browser used, and Personal Information, if provided by the user. You can opt out of our use of tracking pixels and clear gifs on the Website(s) by setting your Cookie Preferences in the Privacy Notification Banner to disable all except functional cookies.

If you arrive at the Website(s) by "clicking through" from another website, then certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Website(s), may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached the Website(s) to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Social Media Features

The Website(s) may include social media features, such as the Facebook, YouTube, LinkedIn, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with social media features are governed by the privacy policies of the companies that provide them and you should review the relevant privacy policies before interacting with these features.

We recognize the importance of safeguarding the confidentiality of your Personal Information. Accordingly, we employ reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Website(s) we cannot, and do not, guarantee the security of any information you transmit on our Website(s), and you do so at your own risk.

Please be aware that third-party websites accessible through the Website(s), including websites/webpages of affiliated companies that are not domiciled in the United States, may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information through linked websites.

We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. We do so in accordance with our data retention policies and applicable law.

The Website(s) are not intended for children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.

If you are a resident of Canada, you may have additional rights to access and control your Personal Information. Exemptions may apply. Consumer privacy rights for Canadian residents include:

Right to Access

You have the right to request access to the Personal Information we collected about you as well as information about our use of your Personal Information and an accounting of the Third Parties, or, if that is not available, the types of Third Parties to whom we disclosed your Personal Information. We may withhold Personal Information or other information that is prohibitively costly to provide, contains information about other individuals, cannot be disclosed for legal, security, or trade secret reasons, is subject to attorney-client privilege, or is otherwise exempt from disclosure under applicable law.

Right to Correction

You have the right to request that we correct inaccurate Personal Information that we maintain about you. After you request to correct inaccurate Personal Information, we will provide instructions for you to provide us with optional documentation to support your request and we will consider it. We may decline to correct your Personal Information if a legal exemption applies such as if we determine, based on the totality of the circumstances, that the information you seek to correct is most likely accurate. If we deny your correction request and you disagree with our finding, you may inform us of your disagreement and we will note that the information is disputed and also inform any Service Providers or Third Parties to who may be in possession of the disputed information of the dispute. We may also decide to delete your allegedly inaccurate Personal Information at the means of correcting it.

Right to Withdraw Consent for Processing

You have the right to request that we stop processing your Personal Information for all purposes or only some purposes. For example, you may request that we stop using your Personal Information to send you commercial email messages. If you request that we stop processing your Personal Information, we will evaluate your request and determine the extent to which we can honor it in accordance with applicable law and will advise you of the consequences of the request. For example, if honoring the request will result in termination of providing services to you, we will let you know.

Exercising Your Rights

You may exercise your privacy rights, our request information about our policies for complying with Canadian privacy laws, by calling us at 800-595-9547, by sending an email to CustomerCare@pens.com, or sending a written request to the following postal address:

Please be specific in your request and provide sufficient information to allow us to locate your Personal Information in our systems based on your request. We may request additional information from you to verify your identity or locate your Personal Information. We will process your request within 30 days subject to possible extensions allowed by law. If we want to exercise a right to an extension, we will inform you.

Responsible Person

The person responsible for our compliance with Canadian federal and provincial privacy laws is our Director, Information Security, Data Privacy, and Compliance who may be reached using the contact information in the “Exercising Your Rights” section above.