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Privacy Policy

Introduction

Peter Gaietto & Associates, Inc. is committed to protecting your privacy. We publish our Privacy Policy so that you can understand our privacy practices and how they help protect your privacy. Peter Gaietto & Associates, Inc. may from time to time handle personal information collected from individuals and companies located within North America.

Scope

This Policy applies to all information collected by Peter Gaietto & Associates, Inc. from which an individual can be identified (“Personal Information”). The Personal Information we collect includes the Employee Information described below as well as certain information including names, email addresses, mailing and billing addresses, telephone and fax numbers, and transaction information collected from customers, potential customers, and end users of our products and services for sales, marketing, order fulfillment, and order delivery purposes.

Notice

Excluding our Employee Information which is discussed below, we collect, process, and use your Personal Information only as a part of our business relationship with you and your company, including contract and billing administration; product and service delivery; fulfilling our business obligations to our customers and resellers; communicating with customers and potential customers about marketing and technical information concerning our products and services; notifying our customers and potential customers regarding important events related to Peter Gaietto & Associates, Inc.; improving our website; and other related business activities of which you are informed at the time your Personal Information is collected or as soon thereafter as practical.

Peter Gaietto & Associates, Inc. collects personally identifiable information about individuals when such individuals specifically provide such information to us on a voluntary basis or while requesting information on our products or services. We may disclose Personal Information to our agents and business partners or to protect and defend the rights or property of Peter Gaietto & Associates, Inc. Peter Gaietto & Associates, Inc. must reply to lawful requests from public authorities, including to meet national security or law enforcement requirements, for disclosure of Personal Information.

Peter Gaietto & Associates, Inc. does not sell, lease, or rent Personal Information to third parties.

Online Information

In general, you may visit our website without providing any Personal Information. However, you may choose to provide us with Personal Information by completing online forms. At the point of collection, we will inform you of how your Personal Information will be used; apart from these uses, Peter Gaietto & Associates, Inc. will only use your Personal Information in accordance with the terms of this Policy.

Use of Cookies

Cookies are small files that a website transfers to your computer’s hard drive through your web browser (if you allow) that enables it to recognize your browser and capture and remember certain information. A cookie cannot read data off of your hard drive or read cookie files created by other sites. Cookies may do things like allow you to navigate faster through the site, remember your preferences and passwords, and generally improve the user experience.

You can turn off the ability to receive cookies by adjusting your browser settings or by clicking on the “cookie settings” link when first arriving on the Peter Gaietto & Associates, Inc. website — please note that if you do so, this may affect the functionality of the website and the information you can access through it.

Peter Gaietto & Associates, Inc. uses cookies to compile aggregate data about website traffic and interaction so that we can offer better site experiences and content in the future. We use third-party companies, such as Google Analytics, to assist us in understanding our site visitors. As part of AdWords remarketing, we use the Google Analytics cookie and others together to inform, optimize, and serve ads based on someone’s past visits to our website. Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Preferences Manager. Google has additional information available about their Remarketing Privacy Guidelines, Policies, and Restrictions.

Social Media and Sharing Tools

Some third-party cookies enable visitors to the Sites to use social media features, like sharing and sending or recommending pages to others. Such third parties include YouTube, Facebook, and LinkedIn. Using these elements of the Sites allows these service providers to set cookies on your device and track your behaviors within their platforms. Social media and sharing tool providers may also detect your presence on the Sites if you are logged into their services.

Please note that the cookies set and tracking carried out by these third-party providers are not under our control. For further information, please view the privacy policies of these third parties.

Setting Your Browser

All browsers permit you to reject and/or delete cookies either one at a time or all at once. The procedure for this depends on the browser you use. While you are able to reject or delete cookies if you no longer wish to store them on your computer, please be aware that some functionalities and services may be reduced or will not work as a consequence.

Employee Information

We collect Employee Information from prospective and present Employees only for legitimate business purposes, including (1) the management and operations of our company, its functions and activities, (2) Employee communications, including Employee surveys, (3) maintaining a directory, (4) carrying out obligations under employment contracts and employment, tax and benefits laws, and in connection with other working relationships or arrangements, (5) development and training programs, (6) recruiting and hiring job applicants, (7) assessing qualifications and performance, (8) performing background checks and verifying references, (9) managing Employee performance, (10) determining Employee compensation or payment, (11) managing the Employee termination process, and (12) other general human resources purposes.

Peter Gaietto & Associates, Inc. will obtain affirmative consent from an Employee before using such Employee’s Personal Information for any purpose other than described above. Employees may decline to provide this consent, and Employees may withdraw their consent at any time.

For legitimate human resources purposes, Employees may choose to voluntarily disclose Personal Information about family members. If our Employees choose to do this, their family member’s Personal Information shall be treated, for the purposes of this Policy, the same as an Employee’s Personal Information. Employee Personal Information is never sold, leased, or rented to any third party. Employee Personal Information will never be disclosed to third parties except as follows: (1) to those retained by Peter Gaietto & Associates, Inc. as agents for the purposes set forth in the paragraph above, (2) where required pursuant to an applicable law, governmental or judicial order, law or regulation, or to protect the rights or property of Peter Gaietto & Associates, Inc., (3) where authorized in writing by the Employee, and (4) where the Employee voluntarily provides Personal Information and the context makes it clear that such information will be provided to a third party.

Choice

We will always give you an opportunity to opt-out before your Personal Information is (1) disclosed to a third party (other than a Peter Gaietto & Associates, Inc. agent doing work at our direction), or (2) used for a purpose that is materially different than that for which it was originally collected or subsequently authorized by you. Although we do not ever anticipate providing sensitive Personal Information to a non-agent third party or using it for a purpose other than that for which it was collected, we will never do so without first allowing the individual involved to affirmatively and expressly consent (opt-in) to such transfer or use.

The only exception to this choice for both sensitive and non-sensitive Personal Information would be where we are required to disclose your Personal Information pursuant to governmental or judicial order, law or regulation to meet national security or law enforcement requirements. At a minimum, you will always be able to opt-out from receiving marketing materials from Peter Gaietto & Associates, Inc. Where applicable law requires that more stringent requirements (opt-in) be applied before you receive marketing material or other communications from us, we will implement the same.

Security

To protect Personal Information collected and stored by Peter Gaietto & Associates, Inc., we have in place reasonable and appropriate technical and operational security measures to prevent Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Data Integrity and Purpose Limitation

We will only collect and retain Personal Information which is relevant to the purposes for which the information is collected, and we will not use it in a way that is incompatible with such purposes unless such use has been subsequently authorized by you. We will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete, and current. We may occasionally contact you to determine that your data is still accurate and current.

Access and Other Rights

You have the right to access, free of charge, obtain a paper or electronic copy, review, correct and update all your Personal Information stored by us, notably to confirm its accuracy. Subject to any relevant legal requirements and exemptions, you may also oppose or limit the processing of your Personal Information or request that certain of your Personal Information be deleted from our files. Employees may review their personnel files and any Personal Information concerning them upon request to their HR partner.

We will make reasonable efforts to comply with the aforementioned requests, unless such requests are prohibited by law, or there is a legitimate purpose to retain your Personal Information, in which case we will inform you without undue delay. We reserve the right to verify your identity before any request relating to your Personal Information processed by us. Please direct any questions about your Personal Information using the contact details provided below.

Recourse, Enforcement, and Liability

Since we are committed to protecting your privacy as set forth in this Policy, if you think we are not in compliance with our Policy, or if you have any question or if you wish to take any other action concerning this Policy or your Personal Information, we encourage you to contact us using the contact details provided below. We will investigate your complaint, take appropriate action and report back to you within 45 days. Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.

Contact

If you have any questions or would like to inquire about our privacy practices and this Policy, the use of your Personal Information, object to or restrict our use of your Personal Information or request deletion or correction of such Personal Information, please contact us at: Peter Gaietto & Associates, Inc. Attn: Privacy Officer Address: 910 Lila Avenue, Milford, OH 45150

Right to Change Policy

In general, changes will be made to this Policy to address new or modified laws. However, we reserve the right to amend this Policy at any time. Appropriate notice will be given concerning such amendments.

Effective: December 1, 2024