Privacy Policy

At Sundyne, LLC, (referred to in this policy, including with respect to its affiliates, as “hmdkontro”, “we”, “us” or “our”), your privacy and the security of your information is very important to us.  We have prepared this Privacy Policy to describe how we collect and process Personally Identifiable Information (defined below) that we gather or receive about (i) visitors to our websites, including www.hmdkontro.com (the “Sites”), (ii) representatives of our potential, current and former authorized channel partners and customers, such as businesses or other organizations that purchase our products or services, including those that sign up for access to our proprietary quote generation platform, “SundQUEST”, our real time order processing system, “Genuine Parts Portal” or who interact with us at live events, including in connection with the SundSCHOOL training program or (iii) job candidates that apply to work with us through our Sites (the foregoing individuals referred to in this policy as “you”, “your” or “user”).  In this context, Sundyne will generally act as a controller in respect of your Personally Identifiable Information which means that we are responsible for and decide why and how your Personally Identifiable Information is processed. This Privacy Policy also contains disclosures with respect to how we collect, use and disclose such information and the rights and choices that may be available to control such processing.

For the purposes of this Privacy Policy, “Personally Identifiable Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular individual or household, as well as any other information related to a particular individual that constitutes “personal information” or “personal data” under applicable privacy or data protection laws.  For the avoidance of doubt, data that has been aggregated or deidentified (as such terms are defined under applicable privacy or data protection laws) and cannot identify, directly or indirectly, an individual, is not Personally Identifiable Information.

This Privacy Policy is effective as of the date it is posted as noted above.  Any links that we provide to third-party websites or services are provided for your convenience and information.  We do not own, operate, control or endorse such third party properties and this Privacy Policy does not apply to any such unaffiliated sites or services.  If you visit any linked third party sites or services, please review any applicable privacy policies. We are not responsible for the content of such unaffiliated sites, any use of such sites or services nor the privacy practices of any third parties.

If the EU Regulation (EU) No. 2016/679 (“GDPR”) or the UK GDPR as defined in the Data Protection Act 2018 (“UK GDPR”) applies to our processing of your Personally Identifiable Information, please see below the section titled “European Data Protection Specific Information” for additional information regarding our collection and processing of your Personally Identifiable Information.

If you are a resident of the state of California, in which case our processing of your Personally Identifiable Information is subject to the California Consumer Privacy Act as amended by the California Privacy Rights Act (the “CCPA”), please see below the section titled “California Specific Information”  for additional information regarding our collection and processing of your Personally Identifiable Information.

 

What Categories of Personally Identifiable Information Do We Collect and How Do We Collect It?

 
The type of Personally Identifiable Information we collect and process depends on how you interact with us (e.g., via our Sites, through the SundQUEST or Genuine Parts Portal platforms, in person at live events), whether on behalf of yourself or in a commercial capacity when you act on behalf of your employer or organization. If you can’t or choose not to provide us with the Personally Identifiable Information we reasonably require, we may be unable to display the Sites, including SundQUEST and Genuine Parts Portal, to you in a manner that you require or to otherwise provide you with the information, products or services you have requested. Generally, we collect and/or process, and in the previous twelve (12) months have collected and/or processed, the following Personally Identifiable Information from or about you via the referenced sources:

Information Collected Directly. We may collect, store and use the Personally Identifiable Information you voluntarily provide to us, including through our Sites and the SundQUEST or Genuine Parts Portal platforms, when you purchase our products or services or interact with us at in-person events. For instance, we may collect identifiers such as your contact information if you provide it to us through the “contact us” form, the “registration” form or through other forms available on the Sites. These forms may ask for additional identifiers, including, in connection with SundQUEST and Genuine Parts Portal, a username and password, or other professional or employment-related information, including your name, the company you work for, your business title, your postal or business address, your email address, your telephone number and other information. In addition, we collect and process commercial information, such as records of services viewed, purchased and obtained and other transaction or purchase history and financial information, such as payment card information and billing address collected and processed via our third party payment processor(s). In addition, if you choose to correspond with us through email, webform or via the chat function on our Sites or through SundQUEST or Genuine Parts Portal, we may retain the content of your email or chat messages together with your email address and the resulting correspondence with you.

Information Collected Automatically.  When you visit the Sites or use certain of our services, such as the SundQUEST and Genuine Parts Portal platforms, some Personally Identifiable Information, such as your internet, usage and other electronic network activity information, is collected automatically. The web servers that we use store the following data by default:

  • The name of your internet service provider
  • The website and browser from which you visited us
  • The websites which you visit when you are with us
  • The amount of time you spend on our Sites or on the SundQUEST or Genuine Parts Portal platforms
  • Your IP address

Automated technologies (e.g., cookies, web pixels or other tracking technologies) we use to collect and process Personally Identifiable Information in connection with your use of the Sites and the SundQUEST or Genuine Parts Portal platforms, such as your internet, usage and other electronic network activity information, include the following:

  • Browser and Device Information: Certain information is collected by most browsers or automatically through your device, such as your device type, operating system name and version, device manufacturer and model, search history and internet browser type and version. We use this information to ensure that the Sites and the SundQUEST or Genuine Parts Portal platforms function properly and to measure, monitor and track traffic activity.
    • IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your internet service provider. An IP address may be identified and logged automatically in our server log files whenever a website visitor accesses the Sites or relevant services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our online services.  We may also derive your approximate location from your IP address to understand from what regions of the world our Site visitors or SundQUEST and Genuine Parts Portal users come.
  • Cookies and other similar technologies: Cookies are pieces of information stored directly on the computer or mobile device that you are using.  Cookies allow us to collect information such as browser type, time spent on the online services, pages visited, referring URL and other aggregated website traffic data. Please refer to our Global Cookie Policy for more information on the cookies we utilize as well as the Client/Prospect Choices and Opt-Out section of this Privacy Policy for information on how you may be able to reject or disable cookies.
    • Additionally, we use Google Analytics to help us analyze how website visitors use our Sites and the SundQUEST and Genuine Parts Portal platforms.  That use may be subject to the Google Analytics Terms of Use and Google Privacy Policy.  For more information about Google Analytics, please review the site “How Google uses information from sites or apps that use our services, located at www.google.com/policies/privacy/partners/. To opt out of Google Analytics specifically, please go to https://tools.google.com/dlpage/gaoptout.
  • Information Collected from Third Party Sources. We may also receive your Personally Identifiable Information (i) when you interact with our pages or accounts on social media sites, such as LinkedIn (e.g., click on our links and/or provide information to us via the relevant account), (ii) through other sources, including the legal entity you are part of (for example if you are designated by a legal entity with whom we have a relationship as its representative) and others who think you might be interested in our products or services or (iii) through third party service providers or channel partners, payment processors, recruitment or staffing agencies, IT service providers, cloud storage providers, data analytics providers or marketing or advertising partners and networks.

 

How Do We Use The Information We Collect?

 

We process your Personally Identifiable Information for the following reasons:

  • To provide operate, improve and enhance our Sites, including the SundQUEST or Genuine Parts Portal platforms, and our other products and services, and to further conduct other internal operations necessary to run our business and provide our products and services to you;
  • To conduct research, analytics and development, including undertaking internal research to provide, develop, customize, maintain and improve the Sites, including the SundQUEST or Genuine Parts Portal platforms, our products, services, facilities, events and other programmatic operations;
  • To provide you with any products or services that you have purchased or signed up for;
  • To register you for our events or enroll you in SundSCHOOL;
  • To send you emails you have opted into receiving, including to inform you of product and service updates, white papers, new products, upcoming events, market research opportunities and other related information from us;
  • To receive any payments you make to us and provide you with a receipt;
  • To recruit and select qualified candidates for employment;
  • To keep in touch, communicate and engage with you, including in response to specific inquiries and requests or to process a transaction;
  • To maintain account integrity and security, as well as to detect, investigate and prevent activities that may violate our policies or be fraudulent or illegal;
  • To engage in business transactions, in the event we engage in a corporate sale, merger, reorganization, financing due diligence, bankruptcy, receivership sale of assets, dissolution, transition of service to another provider or similar event; or
  • To satisfy legal and compliance obligations, including to comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation or other adversarial legal proceedings, protect you, us and others from fraudulent, malicious, deceptive, abusive or unlawful activities and to enforce or investigate potential violations of our Terms of Service or policies

Several of the above purposes for processing may overlap and there may be several purposes which justify our use of your Personally Identifiable Information. Where required by applicable laws or regulations, we will only use your Personally Identifiable Information for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose for such collection.

We also may use the Personally Identifiable Information you provided to us through our Sites, including the SundQUEST or Genuine Parts Portal platforms, in connection with our other services or through email correspondence with us to market to you per the preferences you specified. Our marketing efforts include business-to-business direct marketing and promotional information related to our services or products; however, your Personally Identifiable Information will only be used for marketing purposes if you consent (and you can change your mind at any time as described in the Your Privacy Choices section below).

Additionally, we may use non-identifying information (including deidentified or aggregated data (as such terms are defined under applicable privacy or data protection laws) about your use of the Sites or our products and services to understand and analyze the usage metrics and trends and preferences of our customers, to monitor, analyze the effectiveness of or otherwise improve Sites or products and services and to improve fraud detection and information security, without restriction.
 

Who Do We Share Information With?

 

We will disclose your Personally Identifiable Information only for limited and specified purposes, namely, those described in this Privacy Policy, and we will not “sell” or “share” (as such terms are defined under the applicable data privacy laws) your Personally Identifiable Information to any third party for any purpose.

In addition to any disclosure for which we have received your express consent, we disclose, and have in the previous twelve (12) months disclosed, your Personally Identifiable Information to the following categories of third parties for the following business or commercial purposes:

  • Third party vendors/partners.  We may share your Personally Identifiable Information with our third-party partners, such as channel partners, distributors, and affiliate companies who are able to address or respond to your inquiries, or with our service providers who perform services on our behalf such as information technology consultants,  fraud prevention providers, marketing and advertising partners (including digital marketing agents), data analytics providers, cloud storage providers, payment processors, etc. to develop, provide, support and improve the Sites or our products and services, to maintain and service accounts or provide customer service, for payment processing services or other transactional services, for marketing and advertising purposes, for business continuity purposes, to protect against fraud or abuse or for other internal operations necessary to run our business or provide products and services to you.  If Sundyne uses third-party companies for data processing in order to fulfill any obligations with regard to you, these parties are contractually obligated to handle your data carefully in compliance with the provisions of applicable data privacy laws and according to our instructions and neither to use this data for their own purposes nor to disclose it to third parties.
    • Such Personally Identifiable Information may include: identifiers, professional or employment related information, commercial information, device Information or internet, usage or electronic network activity information.
  • External advisors. We disclose and have disclosed Personally Identifiable Information to our lawyers, accountants, auditors or other external advisors for internal operations necessary to run our business.
    • Such Personally Identifiable Information may include: identifiers, professional or employment related information, commercial information, device Information or internet, usage or electronic network activity information.
  • For legal purposes. Where required or permitted by applicable law or regulation, we disclose or will disclose Personally Identifiable Information to law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations, or otherwise if we believe in good faith that such disclosure is necessary to comply with a legal obligation or request or to enforce our terms and conditions.
    • Such Personally Identifiable Information may include: identifiers, professional or employment related information, commercial information, device Information or internet, usage or electronic network activity information.
  • Potential Business Partners. We may disclose Personally Identifiable Information to actual or prospective acquirers and investors, their representatives and other relevant participants in connection with, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of our business or assets, including in connection with bankruptcy or similar proceedings.
    • Such Personally Identifiable Information may include: identifiers, professional or employment related information or commercial information.

In addition, we may share your Personally Identifiable Information with any other third party where we have your express prior consent.
 

Retention of Personally Identifiable Information

 

We will not retain your Personally Identifiable Information for longer than is necessary to fulfil the purposes explained above; however, we may retain your Personally Identifiable Information for longer if it is considered necessary, for example, in light of actual or potential legal action and to enforce our contractual agreements.

To determine the appropriate retention period for each category of Personally Identifiable Information we collect and process, we consider the amount, nature and sensitivity of the Personally Identifiable Information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your Personally Identifiable Information and whether we can achieve those purposes through other means, and any applicable legal requirements.
 

Data Security and Data Transfers

 

All of the data, including Personally Identifiable Information, we collect is transferred to protected servers in the United States. Only certain individuals who are involved in technical, customer or content support are authorized to access Personally Identifiable Information. We have implemented technical and operational security measures that are designed to secure Personally Identifiable Information from accidental loss and from unauthorized access, use, alteration and disclosure.

Where we transfer Personally Identifiable Information from the EU or the UK to a recipient, such as our subsidiaries, affiliates, service providers or business partners, located outside of the EU or UK to a country which has not been recognized as having an adequate level of data protection, we endeavor to ensure that there is a transfer solution in place to legitimize such transfer (such as the European Commission’s Standard Contractual Clauses under Article 46(2) of the GDPR).  Please contact us if you would like to receive a copy of such Standard Contractual Clauses or request further information in that respect. Where relevant and permissible under the applicable data protection law, we may also rely on one of the derogations under Article 49 of the GDPR or the UK GDPR to transfer your Personally Identifiable Information (such as transfer of data that is necessary for the performance of our contract with you).
 

Your Privacy Choices

 
We strive to provide you with choices regarding your Personally Identifiable Information. We have created the following mechanisms to provide you with control over your information:

Client/Prospect Choices and Opt-Out.

  • Email: We maintain contact lists to communicate with our clients and prospects. All email messages sent to these lists include an opportunity to unsubscribe or opt out of future email messages. You may also request to be removed from future email messages by contacting us via email at: marketing@sundyne.com or privacy@sundyne.com.
  • Cookies: If you do not want information collected through the use of cookies (i.e., you want to opt-out or withdraw consent for such collection), please visit our Cookie Settings tool. Additionally, if your browser or device permits, you may be able to adjust your settings to automatically decline or delete cookies or be given the choice of declining or accepting the transfer to your device of a particular cookie (or cookies) from a particular site. You will need consult the corresponding instructions of the manufacturer for more detailed information on the actual procedure. If you reject or do not accept cookies, you may experience some reduced functionality associated with the Sites or the SundQUEST or Genuine Parts Portal platforms.
    • Some Internet browsers have a “do-not-track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our Sites are not set up to respond to do-not-track signals. We do not permit third parties to use the Sites to collect Personally Identifiable Information about users’ online activities over time and across different websites.

 

Right to Access and Correct Information. If you wish to access or correct any Personally Identifiable Information Sundyne holds about you, you may send an email to privacy@sundyne.com.
 

Children’s and Minor’s Privacy

 

Protecting the privacy of young children and minors is especially important.  For that reason, we do not allow persons under 18 years of age to use the Sites nor access the SundQUEST or Genuine Parts Portal platforms, we do not knowingly collect or maintain information from persons under 18 years of age and no part of our products, services or the Sites, including the SundQUEST or Genuine Parts Portal platforms, are directed to persons under 18 years of age.  If you are under 18 years of age, then please do not use or access the Sites or use our products and services, or otherwise provide us with any Personally Identifiable Information, at any time or in any manner.  To the extent we have any Personally Identifiable Information related to persons under the age of 18, we have no actual knowledge that we “sell” or “share” (as such terms are defined in applicable privacy laws) such individuals’ Personally Identifiable Information.

If you discover that a person under 18 years of age has provided us with information, please alert us at privacy@sundyne.com.
 

Changes to The Policy

 
We may revise this privacy policy from time to time. Any other changes to this Privacy Policy will be posted here and other places we deem appropriate so that you are aware of what changes have been made in how we collect, use and disclose your information.
 

Sundyne Group Companies’ Details and Questions About This Policy

 
Sundyne LLC and all group companies listed below will have access to Personally Identifiable Information on individuals covered by this Policy. However, only those data controllers who administer data about or communicate with individuals will have access to relevant data of individuals.

Sundyne Companies covered by this Policy Contact address Location
Sundyne LLC 14845 West 64th Avenue Arvada, CO 80007 United States of America
Sundyne International S.A. Zi De Dijon
Sud 21600 Longvic
France
Bombas Ercole-Marelli, SL Ctra, Madrid-Toledo
Km.30.8 45200 Illescas
Spain
HMD Sealless Pumps Limited 10-12 Marshal Road
Eastbourne East
Sussex Bn22 9an
United Kingdom
Sundyne Asia Japan Co, Ltd Odakyu Dai-Ichi Seimei Bldg
6F 2-7-1, Nishi-Shinjuku, Shinjuku-ku,
Tokyo, 163-0706
Japan
Sundyne India Sundyne Pumps and Compressors Private Limited
3rd Floor, Westend III,
Aundh, Pune -411 007
India

 

If you have any further questions relating to data protection or regarding the processing of your Personally Identifiable Information, please contact our Data Protection Officer by email at: privacy@sundyne.com.
 

JURISDICTION-SPECIFIC PRIVACY NOTICES

 

European Data Protection Specific Information

 

The following disclosures apply solely with respect to Personally Identifiable Information processing activities that are subject to the GDPR or the UK GDPR.

Legal Basis for Processing Personal Data

Depending on the specific Personally Identifiable Information concerned and the factual context, when we process Personally Identifiable Information, we rely on the following legal bases as applicable:

  • As necessary for our contract: When we enter into a contract directly with you or, if applicable, your employer, we process your Personally Identifiable Information on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage the contract (i.e., providing our products or services to you, as well as facilitating and processing payments, communicating with you about our Sites, including the SundQUEST and Genuine Parts Portal platforms, or our products and services, complying with contractual obligations and related administration). Where we are relying on this legal basis, we may not be able to provide you with all products and services if we do not process your Personally Identifiable Information;
  • Consistent with consent: We rely on your prior consent in order to use certain types of cookies (e.g., analytics cookies we use to perform analysis of our website usage). Where required by law, we also rely on your prior consent to conduct online marketing, including email marketing. You have the right to withdraw your consent at any time by visiting our Cookie Management Tool.
  • As necessary to comply with our legal obligations: We process your Personally Identifiable Information to comply with the legal obligations to which we are subject. This may include detecting, investigating, preventing and stopping fraudulent, harmful, unauthorized or illegal activity and includes compliance with applicable data protection laws. If we do not process your Personally Identifiable Information for these purposes, we may not be able to provide you with all products or services;
  • As necessary for our (or others’) legitimate interests: We process your Personally Identifiable Information based on such legitimate interests to (i) enter and perform the contract with you or your employer; (ii) develop, test and improve our Sites, including the SundQUEST or Genuine Parts Portal platforms, or our other products and services; (iii) ensure authentication, integrity, security and safety of accounts, including to detect, investigate and prevent activities that may violate our policies or be fraudulent or illegal; and (iv) comply with non-EU and non-UK laws, regulations, codes of practice, guidelines or rules applicable to us and respond to requests from, and other communications with, competent non-EU and non-UK public, governmental, judicial or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes and enforce agreements. If we do not process your Personally Identifiable Information for these purposes, we may not be able to perform activities that are necessary for our legitimate interests, and, depending on the circumstances, provide you with our Sites or our products and services.

 

Your Privacy Rights

 

Your rights in relation to your Personally Identifiable Information processed by us as a controller specifically include:

  • Right of access: You have the right to access any Personally Identifiable Information that we hold about you
  • Right of data portability: In some circumstances, you have the right to receive the Personally Identifiable information, which you have provided to us, in a structed, commonly used and machine-readable format and have the right to transfer that data to another provider
  • Right of erasure: In certain circumstances, you have the right to the erasure of Personally Identifiable Information that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected)
  • Right to object to processing: In certain circumstances, you have the right to request that we stop processing your Personally Identifiable Information
  • Right to rectification: You have the right to require us to correct any inaccurate or incomplete Personally Identifiable Information
  • Right to restrict processing: You have the right to request that we restrict processing of your Personally Identifiable Information in certain circumstances (for example, where you believe that the Personally Identifiable Information we hold about you is not accurate or lawfully held)
  • Right to withdraw consent: where our processing of your Personally Identifiable Information is based on your consent, you may withdraw your consent, although withdrawal of consent does not invalidate the consent-based processing that occurred prior to such withdrawal or processing that is not based on consent.
  • Right not to be subject to decision based solely on automated decision making: you have the right not to be subject to decisions based solely on automated processing (i.e., without human intervention), if those decisions produce legal effects or similarly significant effects. If we implement processes that employ automated decision-making which produce legal effects or that significantly affect you, then you shall have the right not to be subject to a decision based solely on automated processing.

This website is maintained by Sundyne LLC, to exercise your rights or if you have any other questions about our use of your Personally Identifiable Information or this Policy, please contact us: by phone at 303-425-0800 or by email at privacy@sundyne.com.  Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to exercise your rights.

You also have the right to lodge a complaint with a supervisory authority in the jurisdiction which is located at the place of your residence.
 

California Specific Information

 

The following disclosures apply solely with respect to our users who qualify as residents of the state of California pursuant to the CCPA.  If you are a California resident, please note that other sections of our Privacy Policy also apply to our processing of your Personally Identifiable Information, and therefore we encourage you to read our Privacy Policy above in its entirety in order to better understand our privacy practices with respect to your Personally Identifiable Information.
 

Notice at Collection

 

As further explained in our Privacy Policy in the sections titled “What Categories of Personally Identifiable Information Do We Collect and How Do We Collect It?”  and “How Do We Use The Information We Collect?”, we may collect or process, and in the previous twelve (12) months have collected and processed, the following categories of Personal Information for the purposes described below:

Categories of Personal Information Collected Purpose of Collection
Identifiers (e.g., name, contact information, username and password, Internet Protocol address or other similar identifiers)
  • To provide our Sites  or our products and services
  • To conduct research and development
  • To communicate with you about our Sites or our products and services
  • To engage in marketing and advertising activities
  • To facilitate payments
  • To engage in business transactions
  • To satisfy legal obligations
Professional or employment related information (e.g., resume, work history and employer)
  • To provide our Sites or our products and services
  • To conduct research and development
  • To communicate with you about our Sites or our products and services
  • To engage in marketing and advertising activities
  • To facilitate payments
  • To engage in business transactions
  • To satisfy legal obligations
Commercial information (e.g., products and services purchased or obtained)
  • To provide our Sites or our products and services
  • To conduct research and development
  • To communicate with you about our Sites or our products and services
  • To engage in marketing and advertising activities
  • To facilitate payments
  • To engage in business transactions
  • To satisfy legal obligations
Device information (e.g., device identifiers, the name of the mobile device operator or internet service provider, browser type, language and time zone)
  • To provide our Sites or our products and services
  • To conduct research and development
  • To communicate with you about our Sites or our products and services
  • To engage in marketing and advertising activities
  • To facilitate payments
  • To engage in business transactions
  • To satisfy legal obligations
Internet, usage or other electronic network activity information (e.g., information, browsing history, search history, and information regarding a consumer’s interaction with our Sites, including the SundQUEST platform, or our products and services, other general activity and diagnostic information)
  • To provide our Sites or our products and services
  • To conduct research and development
  • To communicate with you about our Sites or our products and services
  • To communicate with you about our Sites, including the SundQUEST platform, or our products and services
  • To engage in marketing and advertising activities
  • To facilitate payments
  • To engage in business transactions
  • To satisfy legal obligations

 

We do not collect or process Personally Identifiable Information (including any sensitive Personally Identifiable Information) for the purposes of inferring characteristics about you nor do we use any such information for any other purpose other than as noted above or as expressly permitted by the CCPA and its implementing regulations.

We do not “sell” or “share” (as such terms are defined under the CCPA) your Personally Identifiable Information to any third party for any purpose.  For more information regarding how we may disclose your Personally Identifiable Information, see the section above titled “How Do We Use The Information We Collect?”.

As noted above, we also process Personally Identifiable Information that has been aggregated and/or deidentified as those terms are defined by the CCPA.  Where we process deidentified information, we take reasonable measures to ensure such information cannot be associated with a particular consumer or household, commit to maintain and use such information in anonymized form and not attempt to re-identify such information and contractually mandate third parties to whom we disclose such information to adhere to the same obligations.
 

Our Retention of Your Personally Identifiable Information

 

We retain each category of your Personally Identifiable Information listed in the table above for as long as required to engage in the uses described in this Privacy Policy unless a longer retention period is required by applicable law. Additional detail on retention criteria can be found under “Retention of Personally Identifiable Information” above.
 

Your California Privacy Rights

 
The CCPA provides California residents with the following privacy rights in connection with the collection and/or processing of their Personally Identifiable Information:

  • Right to Know: Know what Personally Identifiable Information we collect about you, including the categories of Personally Identifiable Information collected, the categories of sources from which the Personally Identifiable Information is collected, the business or commercial purpose for collecting, selling or sharing Personally Identifiable Information, the categories of third parties to whom we disclose Personally Identifiable Information and the specific pieces of Personally Identifiable Information we have collected about you;
  • Right to Request Deletion: Request deletion of your Personally Identifiable Information that we have collected or maintained, subject to certain exceptions;
  • Right to Correct: Request that we correct inaccurate Personally Identifiable Information that we maintain about you;
  • Right to be Free from Discrimination and Retaliation: Not receive discriminatory treatment by us for the exercise of your privacy rights conferred by applicable the CCPA, including your right not to be retaliated against for the exercise of these rights; and
  • Right to Opt Out. As noted above, we do not “sell” or “share” Personally Identifiable Information and therefore do not offer a right to opt out of this processing. To opt-out of or withdraw consent with respect to our collection and processing of your Personally Identifiable Information via cookies or other similar technologies for marketing or advertising purposes, please visit Cookie Settings.

As noted above, we do not use or disclose any Personally Identifiable Information (including sensitive Personally Identifiable Information) for the purposes of inferring characteristics about you nor do we use such information for any other purpose other than as noted above or as expressly permitted by the CCPA, and therefore do not offer rights to limit our use or disclosure of such information.

Method to Submit Your Requests. If you wish to exercise any of the rights listed above or if you consider that we have processed your Personally Identifiable Information in violation of applicable law, please email us at privacy@sundyne.com or call us at 1-866-786-3963. You can also submit requests online using the Data Request Form.

Authorized Agents. If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process, including by providing written authorization signed by you directing the agent to act on your behalf. Please note for access, correction and deletion requests, we may require you to verify your own identity with us directly.

Verification Procedures.  To verify your identity and respond to your requests, we will ask you for at least two pieces of Personally Identifiable Information and, for requests for specific pieces of Personally Identifiable Information, we will ask you for at least three pieces of Personally Identifiable Information. The information we require may vary depending on your relationship to us, and may include your full legal name, residential address, email, phone, as well information we may have on file about you or other information that may be necessary to verify your identity. If you are requesting on behalf of another individual, such as a member of your household, we may request additional information from you and/or such individual to verify their identity.

California’s Shine the Light Law.  In addition, under California’s Shine the Light Law (California Civil Code Section 1798.83), if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of Personally Identifiable Information to third parties for such third parties’ direct marketing purposes. We do not share Personally Identifiable Information with third parties for their direct marketing purposes.

This policy was last revised on February 12, 2025