Retail Environments Retail Marketing Retail Execution Our Work About Privacy Policy Effective Date: May 20, 2018 Your privacy is important to GSP Marketing Technologies, Inc. (“GSP”, “we”, “our”, or “us”). It is GSP’s policy to comply with all applicable privacy and data protection laws. To better protect your privacy, we provide this notice explaining our information practices and the choices you can make about the way your information is collected and used. This privacy policy (this “Policy”) describes how we collect, disclose, secure, share, and use the personal information of users of this website, www.gspretail.com (this “Site”). This Policy also applies to personal information we may otherwise collect through our products and services, customer support, third party websites and services, including information collected for marketing purposes. General Principles of GSP’s Collection, Use and Disclosure of Personal Information To the extent required by applicable law, whenever GSP collects personal information, we will: Provide timely and appropriate notice to you about our data practices; Collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected; Process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented; Take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date; Not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”; and Take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within GSP. The Information We Collect When you interact with GSP, we may collect personal information and other information from you. We collect personal information you voluntarily provide us, such as when you register for our marketing activities, when you contact us requesting information via our Site, or submit or respond to one of our surveys. By voluntarily providing us with personal information, you are consenting to our use of it in accordance with this Policy. Information You Provide While using our Site, we may ask you to provide us with certain personal information that can be used to contact or identify you. The types of personal information we collect from our Site and through our sales process, may include: first and last name address, city, state, province, zip code phone number company name title or job function email address Information Automatically Collected When You Use Our Site While using our Site, we and our third-party service providers, such as advertising and analytics providers, collect technical data about you through the use of cookies, web beacons and other similar data technologies. This information is automatically collected when you interact with us through your computer or mobile device and helps us recognize you, customize your user experience and make relevant marketing messages. We may collect technical data about your usage of our Site and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, GSP promotional emails opened, and dates and times of interactions. The types of technical information we collect from our Site may include: IP address, browser information, and device type website usage information tracked with cookies Cookies and Other Tracking Technologies A “cookie” is a small data file of information placed on your computer or device when you visit a website. Cookies and similar technologies allow us to store small amounts of data on your computer or device about your visit to our Site so that we can remember what you did on prior visits. Cookies help us enhance and personalize your experience by saving your preferences, personalizing your online experience, providing you with advertising, which is tailored to your interests, and learn which areas of the Site are useful and which areas need improvement. GSP software utilizes third party tools, which utilize cookies to track visitor activities on our Site. These tools utilize cookies recognize your browser or mobile device and automatically records certain information from your browser. For example, this information may include your computer or mobile device’s internet protocol address, browser type, the webpage you were visiting before you came to our Site, pages of our Site that you visit, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site, for the technical administration of the Site, to increase the Site’s functionality and user-friendliness, and to better tailor the Site to a user’s needs. How to Manage and Disable Cookies If you do not want us to recognize your computer or mobile device, you can disable cookies by configuring your Internet browser to erase all cookies from your computer or mobile device, to block all cookies or to receive a warning before a cookie is stored. You can control the use of cookies at the individual browser level. To prevent new cookies from being installed and to delete existing cookies, please refer to the following link for information on how to manage cookies in commonly used browsers: http://www.allaboutcookies.org/manage-cookies/index.html . If you click on a link to a third-party website, such third party may also transmit cookies to you. This Policy does not cover the use of cookies by any third parties. Please note that you can change the preferences on your browser or mobile device to prevent or limit your computer or mobile device’s acceptance of cookies, but this may prevent you from taking advantage of some of the features on our Site and certain functions of our Site may no longer work, or not correctly, without cookies. If you have any further questions about our cookie practices, please send your questions to privacy@gspretail.com. Below we list the different types of cookies that may be used on the Site: Cookie Description More Information Google Analytics These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the site from and the pages they visited. http://www.google.com/policies/privacy/ Microsoft Dynamics 365 for Marketing Whenever a contact submits a marketing page, Dynamics 365 for Marketing correlates the behavior-analysis cookie ID with the incoming contact data submitted with the marketing-page form. In this way the cookie ID becomes mapped to a Dynamics 365 contact ID, so now we can determine who has been browsing the site. The system applies its configured duplicated-detection method to determine whether incoming landing-page data should be mapped to an existing contact or to a new contact. https://docs.microsoft.com/en-us/dynamics365/customer-engagement/marketing/cookies Twitter Conversion tracking for GSP Software website visitors coming from a Twitter advertisement https://business.twitter.com/en/help/ads-policies/introduction-to-twitter-ads/twitter-ads-policies.html By using the Site, you agree to the processing of your data by third parties in the manner and for the purposes set out above. Please note that each third party has its own privacy policy, which is independent of our Policy. GSP takes no responsibility or liability for the policy and procedures by third parties. Legal Basis for Processing of European Union Data Subjects If you are an individual from the European Economic Area (EEA), GSP’s legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which it was collected. However, we will normally collect personal information from you only where: We have your consent to do so; Where we need the personal information to perform a contract with you (e.g. to deliver the services you have requested); or Where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, GSP may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. How We Use Your Personal Data GSP needs access to certain information to provide you with GSP products and services as described below. GSP uses the information to: provide, update, maintain, and protect our services, tools, websites and business. to comply as required by law, legal process, or regulation to communicate with you in responding to your requests, comments, and questions to resolve technical support inquires to develop and improve product and website features to send emails and other communications for billing, account management, and other administrative matters to send emails for marketing purposes to investigate and help prevent security issues and abuses Third Party Service Providers GSP has relationships with third parties to provide targeted marketing communications and improve the user experience for our customers and prospects. We consequently share information, including personal information, with these contracted third-party service providers in connection with using their services. These third-party service providers may have access to, process or store your personal information for the purpose of providing us with their contracted-for services. These service providers are authorized to use your personal information only as directed by GSP. These service providers are contractually obligated to maintain the confidentiality of the information that GSP provides. We never use, sell or share the personally identifiable information provided to us with third parties for any other purposes and-our service providers are not authorized sell or rent your personal information or use your personal information for a purpose unrelated to the services we have contracted with them for. Compliance with Laws In certain situations, we may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary or appropriate in order to protect our rights, property, or safety of GSP, our users, our employees or others, to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our contracts, or as otherwise required by law. Corporate Events If GSP is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal information may be sold or transferred as part of that transaction. If such an event occurs, we will take appropriate steps to protect your personal information. You will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. Links to Third Party Internet Sites and Plugins Our Sites may contain links to websites or mobile applications that are not operated by GSP and plugins from social media platforms and other third parties. An example of a social media plugin is the “Like” button on Facebook. We provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites, applications, or social media platforms, nor any association with their operators. To learn about the information collected by these third-party websites, applications, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, applications, and social media platforms you visit before using them or providing personal information. International Data Transfers GSP may transfer personal information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Policy. Privacy Shield Frameworks GSP complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. GSP has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@GSPsoft.com. If requested to remove data, we will respond within a reasonable timeframe. We will also provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@gspretail.com. The Privacy Shield will apply to personal information we receive from users in the EU or Switzerland that we collect and use pursuant to this Policy. In particular, GSP remains responsible and liable under the Privacy Shield Principles if third party agents that it engages to process the personal information on its behalf do so in a manner inconsistent with the Principles, unless GSP proves that it is not responsible for the event giving rise to the damage. GSP may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, GSP is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In compliance with the Privacy Shield Principles, GSP commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact GSP at privacy@gspretail.com. GSP has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction. Children GSP’s Sites and Services are not intended for children under 13 years of age. We will not knowingly solicit or collect personal information from or about children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. California Privacy Rights If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. To make such a request, contact GSP at privacy@gspretail.com. Data Retention GSP retains personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. Your Data Retention Rights under the General Data Protection Regulation (GDPR) If you are a resident of an EEA, you have the following data protection rights: If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time. Email your request to the GSP Software Data Protection Officer at privacy@gspretail.com. In addition, you can object to the processing of your personal information, by asking GSP to restrict the processing of your personal information or request portability of your personal information. You can exercise these rights by emailing the GSP Software Data Protection Officer at privacy@gspretail.com. You have the right to opt-out of marketing communications GSP sends you at any time. You can exercise this right by clicking on the “unsubGSP” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by emailing privacy@gspretail.com. If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. You have the right to complain to a data protection authority about our collection and use of your personal information pursuant to GDPR. For more information, please contact your local data protection authority. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm GSP responds to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. NOTE: If you are a resident of a European Union (EU) member state and your personal information is being processed by GSP by or on behalf of one of our customers, our customer is the “Controller” under the GDPR. You will need to communicate with the Controller to exercise your rights under the GDPR. GSP does not govern the data that is processed by our tools. Changes to this Policy Changes to this Privacy Policy will be posted on the Sites. GSP reserves the right to update or modify this Privacy Policy. If we materially change the ways in which we use or share personal information previously collected from you through our Sites or Services, we will notify you through our Services, by email, or other communication. Any modifications will apply only to the personal information we collect after such posting. Who We Are GSP helps consumer-facing businesses transform their growth strategies into store-level results. Our site intelligence software and mobile app optimize planning and enable flawless, store-specific retail execution. Our survey services ensure that retailers know the details of every store to improve capital expenditure decisions, store understanding and store support. Our design services team provides award-winning graphics, photography and visual merchandising solutions tailor-made for retail results. And our point-of-purchase management team leverages expertise in design, production, fulfillment and data management to maximize return on in-store marketing efforts. GSP is headquartered in Clearwater, Florida and maintains production facilities in Clearwater; Provo, Utah and Madison, Wisconsin. If you have privacy related questions that are not addressed in the GSP privacy, then please contact us at privacy@gspretail.com. © GSP Marketing Technologies, Inc. 2018. All Rights Reserved. 14055 46th Street North, Suite 1112 Clearwater, FL 33762 Copyright © 2021 GSP. All Rights Reserved. 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