Universal Clamps, Ltd. (“Universal Clamps”), is a manufacturer of fishing reels, including spinning reels and fly reels. Universal Clamps also provides service for its product lines. The Company is located at 31 Roberts Road, Pine Grove, PA, 17963. Its toll-free phone number is (800) 618-0669.
Universal Clamps does not sell any personal information it gathers of its customers or possesses through automated or other means. The use of personal information by Universal Clamps is limited to disclosures needed to fulfill and carry out the sale of its products. Further, under no circumstances will Universal Clamps discriminate against any buyer or end-user in terms of the quality or prices of the goods and services we offer based on the exercise of any rights afforded under this Policy or any applicable law.
COLLECTION OF PERSONAL INFORMATION
Personal information or personal data is generally defined as information that, by itself or in combination with other information, identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer, device or household (collectively, “Personal Information”). Personal Information can include, but is not limited to, name, address, telephone number, email address, username and password, IP address or other online identifiers, browsing or search history, credit/debit card number or other financial information, professional or employment-related information, office address and other business information, demographic information, consumer preferences, biometric information such as fingerprints, precise location information, or any other type of information that, directly or indirectly, can be linked to or is reasonably capable of being associated with you.
Universal Clamps collects a limited amount of Personal Information relating to individuals who are the ultimate end-users of the products it sells, installs or services. That information can include:
- Full Name
- Billing Address
- Shipping Address
- Phone Number
- Email Address
- Bank Account Information
- Credit Card Information
Personal information is generally collected directly from the customer through Universal Clamps’ website. We may also gather personal information from credit reporting agencies or industry resources. Individuals in our Sales Department may also have occasion to gather personal information during our efforts to deliver product and services to our customer.
USE OF PERSONAL INFORMATION
The primary use of the Personal Information we gather is to assist us in manufacturing and selling our product to our customers. On occasion, we also may use information for the following reasons:
- To provide the customer or end-user with information regarding our products and services
- For testing, research analysis and product development, as well as improvement of our website
We may also use or disclose any of the above categories of Personal Information we collect for one or more of the following reasons:
- To carry out our obligations and/or enforce our payment or other rights arising from any contracts entered between you and us
- To respond to law enforcement requests and as required by applicable law, subpoena, court order, other legal process or governmental regulations;
- As otherwise described to you at or before the point when we collect your Personal Information;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
By providing to Universal Clamps the Personal Information and other data referenced above, you agree that we may use the Personal Information and other data in accordance with the terms of this Policy. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING PERSONAL INFORMATION
We may disclose or share your personal information to a third party for a business purpose related to delivery of our product, related services or securing payment of the purchase price. For example, we may share personal information with an authorized dealer, shipping carrier or other third party associates involved with fulfilling your order. We do so only when the sharing of personal information is in furtherance of the goal of delivering our product and services to our customer. We may also be required to share personal information with our lending institution or credit card vendors solely for purposes of billing and collection. We may also, on occasion, share personal information with our insurers or professional advisors as necessary to carry out our business operations.
We do not sell your Personal Information. Sharing information with any third party is only done in furtherance of or in some way related to performance of our contract with our customer.
Certain areas of the Site(s) may integrate with social media sharing services which will let you share content from the Site(s) with other online services. Your use of such features may enable the sharing of information with your friends or the public, depending on the settings you establish with the relevant social sharing service. Please review the privacy policies of those social media services for more information about how such services handle the information you provide to or share through them.
Universal Clamps neither collects nor sells the Personal Information of minors under 16 years of age.
YOUR RIGHTS AND CHOICES
As indicated earlier in this policy, varying jurisdictions afford to you different rights relating to your Personal Information. Depending on where you reside, those rights can include:
- The right to request access and receive a listing/copy of the Personal Information in the possession of Universal Clamps, as well as the identity of third parties with whom we may have shared the information
- The right to request that your personal information be deleted or expunged from the data and records of Universal Clamps. However, the right to make this request is subject to exceptions. For example, personal information may be maintained, despite a deletion request, if needed to complete a transaction, provide ongoing services, to assist us in meeting our future legal obligations, etc.
- The right to secure correction of any inaccurate personal information; and
- The right to not be discriminated against by Universal Clamps, in terms of the quality and price of the goods and services we offer, because you exercised these rights regarding the collection, use and sharing of your Personal Information.
Any request to exercise your legal rights should be directed to our Data Protection Officer (identified below).
You may be able to opt-out of Universal Clamps sharing your Personal Information with entities identified in this Policy by contacting our Data Protection Officer, unless the sharing of your Personal Information is necessary to perform our duties under a contract or one of the following business purposes: to count ad impressions and evaluate their effectiveness; to detect, protect against, and prosecute security incidents; to debug or troubleshoot functional errors that may arise with the Site(s) and related services; to complete short-term tasks related to an existing interaction you have with Universal Clamps; to maintain or service your account; to process payments and fulfill orders or other transactions you authorize; to verify your customer information; and to ensure the safety and quality of our products and services.
Universal Clamps will do its best to accommodate any request to delete or properly dispose of any copies of your Personal Information, but we cannot guarantee we can eliminate all Personal Information from the specified uses. Therefore, please be as specific as possible in any request to delete or dispose of copies of your Personal Information. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise to perform a contract we entered into with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
If you choose to request that we delete certain portions of your Personal Information, it may affect your ability to use certain parts our Site(s) or other Universal Clamps services. If the request relates to information that Universal Clamps needs to make the Site(s) function properly for you, you may no longer be able to use the Site(s).
You may grant an authorized agent written permission to submit requests regarding your Personal Information. Universal Clamps may request proof of your written permission before responding to any requests made by a supposedly authorized agent. Universal Clamps may deny authorized agent requests if we are unable to verify your identity, or if you cannot provide proof that you authorized the agent to act on your behalf.
Universal Clamps is required to verify the identity of any person or entity that requests the disclosure or deletion of Personal Information. If you have a password-protected account with us, we will use our existing authentication procedures to verify your identity. For most other requests from consumers that do not have a password-protected account with us, Universal Clamps will ask you to provide information that matches at least two pieces of Personal Information we store about you before responding to your request. If you would like to request specific pieces of your Personal Information that Universal Clamps has collected, or if you would like us to delete highly sensitive information, you will need to provide information that matches at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the consumer whose Personal Information you are requesting.
When attempting to verify your identity, we will avoid asking you for more sensitive Personal Information such as your full name, credit/debit card number or banking account information. Instead, we may ask you to provide other types of information to match what we have in our records. For example, we may ask for part of your name or portions of your home address or office address, among other types of information.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Some browsers have a ”do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser ”do not track” signals, but to learn more about how to opt-out of certain kinds of targeted advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific.
DOCUMENT AND DATA RETENTION POLICIES
Universal Clamps does not typically discard or destroy electronic information after the completion of a project. Universal Clamps finds it useful to retain all electronic information relating to the products and services it delivered in its projects.
Electronic data is stored on the network of Universal Clamps. It may also be occasionally found on personal electronic devices used by our employees. Finally, Personal Information may be stored on the systems of our back-up vendors, which information may be encrypted.
Universal Clamps does utilize generally accepted security measures to protect electronically stored information from loss or unauthorized disclosure.
As far as paper documents that contain personal information, Universal Clamps likewise retains paper files for all of the orders. However, if personal information was secured for purposes of quoting an order and the order was not sold, personal information in paper form is generally discarded within 24 months after the matter is closed.
If you reside and interact with Universal Clamps while you are within the European Economic Area (the “EEA,” which includes the 27 European Union Member States, Iceland, Norway and Liechtenstein), Switzerland or the United Kingdom (collectively, the “EU”), then Universal Clamps handles your Personal Information according to the terms of this Policy, unless the exceptions in this section apply, pursuant to the General Data Protection Regulation (“GDPR”).
Universal Clamps will collect, process and use your Personal Information as described in this Policy and for the purposes set forth in this Policy. With the exception of uses for which we have obtained your consent, your Personal Information is processed for reasons necessary to perform our contractual obligations, or in support of legitimate interests as described in this Policy.
Under the GDPR, if you interact with use or our Site(s) while in the EU, you have the following rights regarding Universal Clamps’ handling of your Personal Information:
- the right to update and correct any inaccurate Personal Information we hold about you;
- the right to request details on the Personal Information we hold about you at any time;
- the right to withdraw any consent for marketing activities or processing of Personal Information that you might have provided to Universal Clamps;
- the right to request erasure of Personal Information;
- the right to request restriction of Universal Clamps’ processing of your Personal Information;
- the right to object at any time to Universal Clamps’ processing of Personal Information concerning you; and
- the right to request the portability of Personal Information that you have provided to Universal Clamps.
DATA PROTECTION OFFICER
The Data Protection Officer of Universal Clamps is:
Stacey L. Header, CFO
Data Protection Officer for Innovative Reel Technologies, Ltd.
31 Roberts Road
Pine Grove, PA 17963
In the event you (or your authorized agent) wish to exercise any of your rights under this Policy or applicable law, or have any questions regarding the Policy, please direct a written request in person or by US Mail to Ms. Header or the current Data Protection Officer at the above address.
Universal Clamps will endeavor to respond to a verifiable consumer request within 30 days of receipt of the request. We will verify the request by comparing or corroborating the request with information in our possession. If more time is required, we will inform you of the reason and extension period in writing. In the event we find it necessary to charge a fee because of the scope of the request, we will notify you and provide a cost estimate before completing your request.
Under the GDPR, if you are in the EU you also have the right to lodge a complaint about Universal Clamps’ processing of your Personal Information with a supervisory authority. In particular, you may lodge a complaint in the Member State where you live or work or where the alleged violation took place.
To protect your Personal Information, Universal Clamps’ Site(s) use appropriate technical and organizational security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information and other data stored on our Site(s).
Universal Clamps retains Personal Information for as long as necessary to fulfill the stated purpose for which the Personal Information was collected or otherwise processed, and thereafter for a variety of legitimate legal or business purposes. These may include retention periods that are: (i) mandated by law, contract or similar obligations applicable to Universal Clamps’ business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records.
Your Personal Information may be disclosed to and processed by staff operating in the United States. Disclosure will be to individuals who work for Universal Clamps, our subsidiaries, related companies, and companies with which we have contracted to process or store this data on our behalf. The individuals and organizations that receive Personal Information as a result of international transfers out of the EU must follow our express instructions with respect to the use of Personal Information and they must comply with appropriate security measures to protect your information.
Universal Clamps’ Site(s) and services are intended for individuals 18 years of age and older. Our services are not directed at, marketed to, nor intended for, children under 18 years of age. Universal Clamps does not knowingly collect or sell any information, including Personal Information, from children under 18 years of age. If Universal Clamps learns that it has collected any information regarding a person younger than 18 years of age, Universal Clamps will delete or destroy the information immediately.
If there is concern that information regarding a person younger than 18 years of age was somehow collected by Universal Clamps, any minor, or the parent(s) or legal guardian(s) of such minor, who wishes to request the removal of the minor’s information should submit their request by contacting our Data Protection Officer.
The Site(s) may contain links to external website or applications, including those embedded in third-party advertisements or sponsor information, that are not controlled by Universal Clamps. Universal Clamps is not responsible for the privacy practices and data collection policies for such third-party sites. You should consult the privacy policies of those sites for details.
We reserve the right to amend this Policy in our discretion at any time. Any amendments will be posted on our Site. Since this Policy may change over time as we modify or expand our business, we suggest that you check back from time to time in order to understand how we treat your information. Our Policy’s effective date will always be set forth at the beginning and end of the Policy. Any changes will be immediately incorporated into this Policy, and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so.
Any change to this Policy is effective immediately. Your continued use of the Site(s) or our services after any changes are made to this Policy constitutes your acceptance of the changes. If any changes are unacceptable to you, you should cease all use of the Site(s) and our services.
If we make a change that will substantively affect how we use and/or share Personal Information that Universal Clamps already collected from you, we will attempt to provide appropriate notice to you, and give you thirty (30) days to opt-in to the changes as they pertain to your information. If you do not opt-in, your information will continue to be used in a manner that is consistent with the version of this Policy under which it was collected, or the information will be deleted.
If you are unable to understand or implement this Policy, please contact the Data Protection Officer to develop an alternate means of securing information or assistance. If you need assistance making a request or inquiry under this policy and cannot submit a written request, call our toll-free phone number at (800) 618-0669.
Edition: Jan. 2020, as amended March 11, 2020