3E Company Environmental, Ecological and Engineering, LLC and its affiliates (“3E,” “we,” or “us”) respects your concerns about privacy. This Privacy Notice ( “Privacy Notice”) outlines how we, when acting as a data controller, collect, use, disclose and otherwise process your personal data when you interact with us as a representative of our business customers and business partners, such as information we collect through our websites, social media accounts, mobile applications (collectively, our “Digital Properties”), or when you contact our hotline service, and through other online and offline interactions. If you are a job applicant, 3E’s Global Job Candidate Privacy Notice should be read together with this Privacy Notice.

The Notice describes the categories of personal data we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Privacy Notice also describes your rights regarding your personal data that we hold about you and how you can request access to, correct of, object to or restrict processing of, portable copies of, and erasure of your personal data.

We will only process your personal data as described in this Privacy Notice unless otherwise permitted or required by applicable law.

Updates: We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates. If any of these changes are unacceptable to you, you should stop interacting with us.

1. How We Obtain Information About You

We may collect personal data about you from the following sources:

  • Directly From You. We may collect personal data you provide to use directly, such as when you contact us through our Digital Properties or customer hotline, interact with us in person at an event or tradeshow, sign up for offers or newsletters, communicate with us, or sign-up our products or register your account.
  • Data Collected Automatically and Through Tracking Technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies. This may include information about how you use and interact with our Digital Properties or otherwise interact with us and our products, and information from and about your device, internet usage, and Digital Property activity.
  • From Third Parties. We may collect personal data from third parties, such as business partners or authorized resellers of 3E products, public sources, social media companies, or from others interacting with us.

We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use or disclose it for the purposes identified below.

2. Information We Collect

The type of personal data we collect depends on how you interact with us. We may collect the following types of personal data:

  • Basic identifiers, such as your name, email address, telephone number, and business contact information.
  • Commercial information, such as purchase or subscription information, information about products you or your business contacts order or are interested in, and other commercial or financial information.
  • Electronic information/internet activity, such as data gathered by technology when you visit our website, use our mobile application, or interact with us online (such as IP address, browser information, operating system type, device type). For more information about cookies and other device data, please see Section 5 of this Privacy Notice.
  • Professional or employment-related information, such as job title, organization, or other professional information.
  • Audio recordings, such as when you contact our hotline services or when you are contacted by one of our sales representatives (subject to your consent).
  • Inferences drawn from any of the information we collect to create a profile about you.

3. How We Use Personal Data

We may use personal data that you provide to us for the for the following purposes:

  • To provide you or your company with products and services, such as providing you the goods and services you or your company requests; providing customer service; processing or fulfilling orders and transactions, verifying customer information; maintaining internal business records; communicating with you about your product, service, or subscription; responding to requests, complaints, and inquiries; and providing similar services and otherwise facilitating your relationship with us.
  • For our internal business purposes, maintaining or servicing accounts; operating our Digital Properties; and maintaining internal business records.
  • For our internal research and product improvement purposes, such as verifying or maintaining the quality of our products or services; developing new products or services, improving our existing products and services; customizing advertisements to you and performing market research; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
  • For legal, safety or security reasons, such as complying with legal and reporting requirements; investigating and responding to claims against the Company and its customers; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
  • In connection with a corporate transaction, such as if we acquire, or some or all of our assets are acquired by, another entity, including through a sale in connection with bankruptcy and other forms of corporate change.
  • For marketing, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use personal data we collect to send you newsletters, surveys, questionnaires, promotions, or information about events, webinars, or trade shows. You may unsubscribe to our email marketing via the link in the email or by contacting us as set forth in Section 12 below.
  • In a de-identified or aggregated format, we may also use or disclose your information in a de-identified or aggregated format for any purpose permitted by law.
  • For any other purposes for which you provide consent.

If you are an individual located in the EEA, the United Kingdom, or Switzerland, 3E processes personal data in compliance with the GDPR, ensuring a lawful basis for each processing activity. The basis varies depending on the data type and the context of our collection. Our processing activities typically fall under these lawful bases:

  • Contractual necessity, such as when processing is required to fulfill our contractual duties to you.
  • Legal obligation, such as processing data when it is necessary to comply with applicable laws or to protect the rights, safety, and property of 3E, our affiliates, customers, or third parties.
  • Legitimate interests, such as when we process data for purposes that are in our legitimate interests, such as securing our products or services, communicating with you, and improving our products or services. This processing is done only when these interests are not overridden by your data protection rights or your fundamental rights or freedoms.
  • Consent, such as when we process data when you have explicitly consented to such processing. When we rely on consent as the legal basis, you have the right to withdraw your consent for data processing at any time.

4. Who may have access to your personal data

We may disclose personal data to third parties, including the categories of recipients described below:

  • To other companies in the 3E group of companies, which includes parents, corporate affiliates, subsidiaries, business units and other companies that share common ownership with 3E, including some 3E affiliates located outside of the United States.
  • Our service providers that work on our behalf, such as third parties that assist us with marketing efforts and IT and hotline service providers.
  • For legal, security, or safety purposes, we may disclose your information to third parties, law enforcement, or other government agencies to comply with law or legal requirements; to enforce or apply our Terms of Use and other agreements; to protect our rights and the property or safety of our users or third parties; and to professional consultants, such as accountants, lawyers, and financial advisors.
  • In connection with a corporate transaction, such as if we, we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

5. Cookies and Other Tracking Technologies

3E’s websites (and authorized third parties) collect information, via cookies, web beacons, pixels, tags, session replay tools, or other tracking technologies, such as your Internet Service Provider and IP address, the data and time you access 3E’s websites, the pages you have accessed while visiting 3E’s website, and the Internet address from which you accessed the 3E websites.

  • Cookies are a type of technology that install a small amount of information on a user’s computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.
  • Pixels, web beacons, and tags are types of code or transparent graphics that contain a unique identifier. These technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user’s computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.
  • Session replay tools record your interactions with 3E websites, such as how you move throughout 3E websites and engage with our webforms and products.

We and our service providers use these technologies to remember user preferences; browsing behavior; to track your activity across Digital Properties over time; to maximize the performance of our website, products, and services; provide you with information that may be of interest to you, measure the effectiveness of our email campaigns, and personalize online content. For example, we use Google Analytics to help us improve our Digital Properties, performance and user experiences. Google Analytics may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.

You may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser.

6. Data Transfer

We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries (such as the U.S.), we implement appropriate safeguards to protect your personal information in accordance with this Privacy Notice.

The U.S. Department of Commerce administers the Data Privacy Framework (“DPF”) Program, including processing submissions for self-certification and re-certification to the EU.-U.S. DPF Principles, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles (collectively, the “DPF Principles”). 3E will continue to participate in and comply with the relevant DPF Principles.

If you are located in the United Kingdom (“UK”), European Economic Area (“EEA”) or Switzerland, 3E has certified to the EU-U.S. and Swiss-U.S. Data Privacy Frameworks for the transfer of personal data from the EEA and Switzerland, as well as the UK extension for the transfer of personal data from the United Kingdom to the United States, as described further in our Data Privacy Framework Notice. To learn more about the EU-U.S. and Swiss-U.S. Data Privacy Frameworks, and the UK extension, please visit www.dataprivacyframework.gov/s/. To view 3E’s certification, please visit www.dataprivacyframework.gov/s/partipant-search.

7. Your Rights and Choices

Depending on which laws apply to your personal information, you may have the following rights in relation to personal data that we hold about you:

  • To request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
  • To request that we rectify or update your personal data that is inaccurate, incomplete or outdated.
  • To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
  • To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
  • Where you have given us consent to process your personal data, to withdraw your consent; and
  • To request that we provide a copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstance.

You may contact us by e-mail or as described in the “How to Contact Us” section below to exercise your rights described above.

You also have the right to lodge a complaint with the data protection supervisory authority in your country. You can find the contact information of the data protection supervisory authority in your country here (for EU citizens) and here (for UK citizens).

8. Data Security

3E maintains reasonable security procedures and technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, disclosure, alteration, or use.

9. How Long We Keep Your Personal Data

Your personal data will be retained as long as necessary to fulfill the purpose for which we collected it. This includes retaining your personal data to:

  • Provide you with the products or services you or your company have requested and interact with you
  • Maintain our business relationship with you or your company
  • Improve our business over time.
  • Ensure the ongoing legality, safety, and security of our services and relationships; or
  • Otherwise in accordance with our internal retention procedures.

Once you or your company have terminated your relationship with us, we may retain your information in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest. We will then delete the personal data, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).

10. Children’s Privacy

Interactions with us are intended for individuals 16 years of age and older. Our interactions are not directed at, marketed to, nor intended for children under 16 years of age. 3E does not knowingly collect any information, including personal data, from children under 16 years of age. If you believe that we have inadvertently collected personal data from a child under the age of 16, please contact us using the information in Section 12 below.

11. External Links

When interacting with us, you may encounter links to external sites or other online services. We are not responsible for the privacy practices and data collection policies for such third party services. You should consult the privacy notices of those third party services for details.

12. How to Contact Us Regarding Privacy Inquiries

If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data, or if you would like to exercise your data subject rights, you may contact us:

By email at: privacy@3eco.com

In writing at:
3E
Attention: Privacy Team
3207 Grey Hawk Court, Suite 200
Carlsbad, California 92029 USA

Our EU Representative

If you are located in the European Union (“EU”) and have any questions or comments about this Notice, any issue relating to your personal data, or if you would like to exercise your data subject rights, you may contact our EU representative. Please include your name and the name of the business (3E) to which your request refers.

By email at: privacy@3eco.com

In writing at:
3E Europe GmbH
Attention: Privacy Team
Bergheimer Str. 3
88677 Markdorf, Germany

Our UK Representative

If you are located in the UK and have any questions or comments about this Notice, any issue relating to your personal data, or if you would like to exercise your data subject rights, you may contact our UK representative. Please include your name and the name of the business (3E) to which your request refers.

By email at: datarequest@datarep.uk (quoting “3E” in the subject line)

In writing at:
DataRep
Attention: 3E – Privacy Notice
107-111 Fleet Street,
London,
EC4A 2AB
United Kingdom

US State Law Requirements

Some U.S. state privacy laws, such as the California Consumer Privacy Act (“CCPA”), require specific disclosures for state residents. This Notice is designed to help you understand how 3E handles your information. In the sections above, we explain (1) the categories of personal data 3E collects and the sources of that information; (2) how 3E uses personal data; (3) when 3E may disclose that information; and (4) how 3E retains information. 3E does not sell or “share” (as defined in the CCPA) your personal data.

As of January 1, 2023, if you are a resident of California, the CCPA also provides the right to request information about how 3E collects, uses, and discloses your information. And they may give you the right to access and correct your information, and to request that 3E delete that information. Finally, 3E provides the right to not be discriminated against for exercising these privacy rights.

If you have questions or concerns related to your rights under the CCPA, or would like to exercise your rights, you (or your authorized agent) may contact 3E at privacy@3eco.com. The CCPA also requires a description of data practices using specific categories. This table uses these categories to organize the information in this policy.

CATEGORIES OF INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (personal information). In particular, we have collected personal information in the following categories from consumers within the last 12 months:

DISCLOSURE OF PERSONAL INFORMATION FOR BUSINESS PURPOSES

In the preceding 12 months we have disclosed the above categories of personal information and sensitive personal information for business purposes, including: (a) to provide you or your company with products and services, (b) for our internal business purposes; (c) for our internal research and product improvement purposes; (d) for legal, safety or security reasons; (e) in connection with a corporate transaction; and (4) for marketing, as well as for administrative purposes, to our service providers and contractors, including those for web analytics, data processing, auditing, and other administrative purposes. The service providers and contractors are obligated not to disclose or use personal information outside of the business relationship with us or for purposes not permitted in their contract with us.

USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

We do not use or disclose sensitive personal information except in connection with those business purposes permitted under Section 1798.121 of the CCPA, including to perform services on behalf of our business.

SUPPLEMENTAL INFORMATION FOR RESIDENTS OF CALIFORNIA

(1) Right to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

(a) The categories of personal information we have collected about you;
(b) The categories of sources from which the personal information was collected;
(c) The business or commercial purpose for collecting, selling, or sharing personal information;
(d) The categories of third parties to whom we disclose personal information; and
(e) The specific pieces of personal information we have collected about you (subject to exceptions and restrictions set forth in California privacy law regulations regarding disclosure of certain personal information).

(2) Right to Delete Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers and contractors to delete) your personal information from our records, unless an exception applies (for example, if we are required by law to retain that information). If your request is denied, the response we provide to your verifiable consumer request will explain the reason for denying your request.

(3) Right to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate personal information that we maintain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will correct (and direct our service providers and contractors to correct) inaccurate personal information that we maintain about you, unless an exception applies. If your request is denied, the response we provide to your verifiable consumer request will explain the reason for denying your request.

(4) Right to Opt-Out of the Sale or Sharing of Personal Information

We do not sell or share (as defined under the CCPA) personal information that we collect from you and therefore do not provide a method to opt-out from such activities.

(5) Right to Limit Use of Sensitive Personal Information

We do not use or disclose sensitive personal information that we have collected from you for purposes other than those business purposes permitted under Section 1798.121 of the CCPA and therefore do not provide a method to limit such activities.

Our Verification Process

Upon receipt of your request, we will provide directions on identity verification requirements which will include submission of pieces of personal information that we can match to our records. Once you provide such information and assuming we are able to verify your identity by matching the information you provided to our records, we will begin to gather information to respond to your request. For requests to correct, we may require you to provide additional documentation to rebut any of our own documentation that the personal information that you are requesting to correct is accurate.

No later than 10 business days after receiving your request, we will confirm receipt of the request and provide information about how we will process the request. We will endeavor to respond to a verifiable consumer request within 45 calendar days of its receipt. If we require more time (we may take up to 45 additional days), we will inform you of the reason and extension period in writing. If we cannot verify the request within the 45 calendar days, we may deny the request. If we deny your request, we will inform you of the reason for its denial.

Authorized Agents

You may use an authorized agent to submit a request to know, request to delete, or request to correct on your behalf. The authorized agent can submit such requests on your behalf by contacting us at privacy@3eco.com.

When you use an authorized agent to submit a request to know, request to delete, or request to correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (1) verify your own identity directly with us; or (2) confirm directly with us that you provided the authorized agent permission to submit the request.

Contact Information

If you have any questions or concerns about our privacy policies or information practices, including, but not limited to, the ways in which we collect and use your personal information, or your choices and rights regarding such use, or if you wish to exercise your data subject access rights, please do not hesitate to contact: privacy@3eco.com. This Privacy Notice may be found on www.3eco.com.