FirstESource.com (referred to as the "Site") is composed of electronic commerce
platforms predominantly used by business entities to facilitate electronic commerce
and such business use. The Site does not generally involve the collection of personal
information of individuals. FeS recognizes the importance of privacy as well as
the importance of maintaining the confidentiality of any personal information. This
Privacy Policy applies to all products and services featured on our site and sets
out how we may collect, use and disclose information in relation to users of the
Site.
You may use our services and products via a mobile device, either through mobile
applications or mobile optimized websites. This Privacy Policy also applies to the
use of our services and products.
A. COLLECTION OF INFORMATION
1. Your privacy is important to us and we have taken steps to ensure that we do
not collect more information from you than is absolutely necessary for us to provide
you with our services and to protect your account.
2. Information including, but not limited to, user name, address, phone number,
fax number and E-mail address ("Registration Information") may be collected at the
time a user registers on the Site.
3. In connection with any transaction and payment services or services under our
buyer protection plans we provide on the Sites, information, including but not limited
to, bank account numbers, billing and delivery information, credit/debit card numbers
and expiration dates and tracking information from check payment or money orders
("Account Information") may be collected to, among other things, facilitate the
sale and purchase as well as the settlement of the purchase price of the products
or services transacted on or procured through the Site.
4. We record and retain details of users’ activities on the Sites. Information relating
to such transactions including, but not limited to, the types and specifications
of the goods, pricing and delivery information and any trade dispute records (“Activities
Information”) may be collected when sale and purchase transactions are conducted
on or facilitated through the Site.
5. From time to time, we collect information about our users and prospective users
during trade shows, industry events and other functions. The information we may
collect at these locations may include, but is not limited to, user name, address,
phone number, fax number and email address ("Event Information").
6. We record and retain records of users' buying and browsing activities on our
platform, including but not limited to IP addresses, browsing patterns and buyer
behavioral patterns. In addition, we gather statistical information about the Site
and visitors to the Site including, but not limited to, IP addresses, browser software,
operating system, software and hardware attributes, pages viewed, number of sessions
and unique visitors (together "Browsing Information").
7. Registration information, browsing activity information, account information,
activities information and event information generally relate to business entities.
Together, these are referred to as business activity data (“Business Data”). Insofar
and only insofar as they constitute personally identifiable data of living individuals,
such information together is referred to as personal data (“Personal Data”).
8. It is mandatory for users of the Site to provide certain categories of Business
Data and Personal Data (as specified at the time of collection). In the event that
users do not provide any or sufficient Business Data and/or Personal Data marked
as mandatory, we may not be able to complete the registration process or provide
such users with our products or services.
B. USE OF PERSONAL DATA
If you provide any Personal Data to us, you are deemed to have authorized us to
collect, retain and use that Personal Data for the following purposes:
1. Verifying your identity;
2. Verifying your eligibility to register as a user of the Site;
3. Processing your registration as a user, providing you with a log-in ID for the
Site and maintaining and managing your registration;
4. Providing you with customer service and responding to your queries, feedback,
claims or disputes;
5. Facilitating communication between sellers and buyers on the Site;
6. Performing research and/or statistical analyses in order to improve the content
and layout of the Site, improving our product offerings and services and for marketing
and promotional purposes;
7. Subject to obtaining your consent in such form as may be required under the applicable
law, we may use your name, phone number, residential address, E-mail address and
fax number ("Marketing Data") to provide notices, product alerts, surveys and other
communications and other marketing materials to you. These relate to goods and services
offered by us on the Site. Examples are our Custom Package Membership, Gold manufacturers / Suppliers
Membership, Silver Membership, Verified Members Membership, Free Members Membership
(individually referred to as a “Membership” and collectively called the “Memberships”).
8. If you voluntarily submit any information to the Site for publication on the
Site through our publishing tools, including but not limited to, Company Profile,
Product Catalog, Trade Leads, and input to any discussion forum, then you are deemed
to have given consent to the publication of such information on the Site ("Voluntary
Information"); and
9. Making such disclosures as may be required for any of the above purposes or as
required by law or in respect of any claims or potential claims brought against
us.
C. DISCLOSURE OF PERSONAL DATA
1. You further agree that we may disclose and transfer (whether within or outside
the jurisdiction of the FeS entity that you are contracting with) your Personal
Data to service providers engaged by us to assist us with providing you with our
services (including but not limited to data entry, database management, promotions,
products and services alerts, delivery services, payment extension services, and
membership authentication and verification services) ("Service Providers"). These
Service Providers are under a duty of confidentiality to us and are only permitted
to use your Personal Data in connection with the purposes specified at B.1 to B.9
above, and not for their own purposes (including direct marketing).
2. You agree that we may disclose and transfer (whether within or outside the jurisdiction
of the FeS entity with which you are contracting), for the purposes specified at
B.1 to B.9 above, your Personal Data to other affiliated companies within the FeS
Group, which comprises a group of companies operating leading online and mobile
marketplaces in consumer and business-to-business commerce, as well as cloud computing
and other services.
3. When necessary we may also disclose and transfer (whether within or outside the
jurisdiction of the FeS entity with which you are contracting) your Personal Data
to our professional advisers, law enforcement agencies, insurers, government and
regulatory and other organizations for the purposes specified at B.9 above.
4. Any Personal Data supplied by you will be retained by us and will be accessible
by our employees, any Service Providers engaged by us and third parties referred
to at C.2 and C.3 above, for or in relation to any of the purposes stated in B.1
to B.9 above.
5. All Voluntary Information may be made publicly available on the Sites and therefore
accessible by any internet user. Any Voluntary Information that you disclose to
us becomes public information and you relinquish any proprietary rights (including
but not limited to the rights of confidentiality and copyright) in such information.
You should exercise caution when deciding to include personal or proprietary information
in the Voluntary Information that you submit to us.
6. We may share your Account Information with vendors or banks to enable your transactions
on the Sites to be completed. In addition, we may use your Account Information to
determine your credit-worthiness and, in the process of such determination, we may
need to make such Account Information available to banks or credit agencies. While
we have in place up-to-date technology and internal procedures to keep your Account
Information and other Personal Data secure from intruders, there is no guarantee
that such technology or procedures can eliminate all of the risks of theft, loss
or misuse.
7. We may provide statistical information to third parties, but when we do so, we
do not provide personally-identifying information without your permission.
8. We have established relationships with other parties and websites to offer you
the benefit of products and services which we do not provide. We offer you access
to these other parties and their websites either through the use of hyperlinks to
those sites from the Site or through offering "co-branded" sites in which both we
and other parties share the same uniform resource locator, domain name or pages
within a domain name on the Internet.
In some cases you may be required to submit personal information to register or
apply for products or services provided by such third parties or co-branded and
affiliate partners. This Privacy Policy does not apply to these third party sites
or co-branded sites. The privacy policies of those other parties may differ from
ours, and we have no control over the information that you submit to those third
parties. You should read the relevant privacy policy for those third party sites
and co-branded and affiliate sites before responding to any offers, products or
services advertised by those parties.
D. RIGHT TO ACCESS/CORRECT PERSONAL DATA
Under the applicable laws, you have the right of access to personal information
held by us and to request correction of the information.
If you have any questions regarding this Privacy Policy or if you wish to access
or correct your Personal Data, you may send your request in writing to the following
address:
Legal Counsel, The Legal Department
First Engineering Source, Inc.,
P.O. Box 1019, Westmont, IL 60559, USA
In accordance with the applicable laws, we reserve the right to charge you a reasonable
fee for the processing of any data access or correction request.
E. COOKIES
We use "cookies" to store specific information about you and track your visits to
the Sites. It is not uncommon for websites to use cookies to enhance identification
of their users.
A "cookie" is a small amount of data that is sent to your browser and stored on
your computer's hard drive. A cookie can be sent to your computer's hard drive only
if you access the Site using a computer. If you do not de-activate or erase the
cookie, each time you use the same computer to access the Site, our web servers
will be notified of your visit to the Site and in turn we may have knowledge of
your visit and the pattern of your usage.
Generally, we use cookies to identify you and enable us to a) access your Registration
Information or Account Information so you do not have to re-enter it; b) gather
statistical information about usage by users; c) research visiting patterns and
help target advertisements based on user interests; d) assist our partners to track
user visits to the Sites and process orders; and e) track progress and participation
in promotions.
You can determine if and how a cookie will be accepted by configuring the browser
which is installed in the computer you are using to access the Site. If you choose,
you can change those configurations. By setting your preferences in the browser,
you can accept all cookies or you can choose to be notified when a cookie is sent
or you can choose to reject all cookies. If you reject all cookies by choosing the
cookie-disabling function in your browser, you may be required to re-enter information
on the Site more often and certain features of the Site may be unavailable or inoperable.
F. MINORS
The Sites and their contents are not targeted to minors (those under the age of
18) and we do not intend to sell any of our products or services to minors. However,
we have no way of distinguishing the age of individuals who access our Site. If
a minor has provided us with personal information without parental or guardian consent,
the parent or guardian should contact our Legal Department at the address set out
in paragraph D above to remove the information.
G. SECURITY MEASURES
We employ commercially reasonable security methods to prevent unauthorized access
to the Site, to maintain data accuracy and to ensure the correct use of the information
we hold.
For registered users of the Site, your Registration Information and Account Information
(if any) can be viewed and edited through your account, which is protected by a
password. We recommend that you not divulge your password to anyone. Our personnel
will never ask you for your password in an unsolicited phone call or in an unsolicited
E-mail. If you share a computer with others, you should not choose to save your
log-in information (e.g., user ID and password) on that shared computer. Remember
to sign out of your account and close your browser window when you have finished
your session.
No data transmission over the Internet or any wireless network can be guaranteed
to be perfectly secure. As a result, while we try to protect the information we
hold for you, we cannot guarantee the security of any information you transmit to
us and you do so at your own risk.
H. CHANGES TO THIS PRIVACY POLICY
Any changes to this Privacy Policy will be communicated by us posting an amended
and restated Privacy Policy on the Site. Once posted on the Site the new Privacy
Policy will be effective immediately. You agree that any information we hold about
you (as described in this Privacy Policy and whether or not collected prior to or
after the new Privacy Policy became effective) will be governed by the latest version
of the Privacy Policy.
I. YOUR INPUT AND FEEDBACK
We welcome your input regarding our Privacy Policy and any comments on the services
we provide to you. You may send us your comments and responses by post to:
The Legal Department, FirstESource.com
First Engineering Source, Inc.,
P.O. Box 1019, Westmont, IL 60559, USA
