Customer, Supplier, and Partner Portals

Envita Solutions, LLC and its subsidiaries (“Envita,” “we,” “us,” “our”) is committed to protecting the privacy of your information. The following Privacy Policy sets forth our policies and practices regarding the collection, use, and disclosure of the information we receive through your use of our customer, supplier, and partner collaboration and data sharing portals, including, but not limited to, the IS2 Data Management Portal, and other Internet or email based services, registrations and surveys (each a “Portal”).

Effective Date

This Privacy Policy is effective as of 01/01/2018.

Information We Collect

We collect different types of information from Portal users and responders to email surveys and registrations.

Personal Information

We may collect personally identifiable information that you voluntarily provide to us, including your first and last name; company name and address; email address; telephone number; and your username and password for accessing the Portal (collectively, “Personal Information”).

Usage Information

We may collect additional information from you regarding your activities on the Portal (collectively, “Usage Information”). If you log into a Portal with your unique username and password, then we may associate your Usage Information with your identity. When you use a Portal that does not require you to log in with unique user credentials, then we may collect anonymous Usage Information that may not by itself reasonably identify you as the source. Usage Information may include your IP address; “click stream” activity, such as when you click on a banner advertisement; the type of Internet browser and computer operating system you are using; the location from which you are accessing the Portal; the URL of the website from which you linked to our Portal; the areas of our Portal you visited; and the actions you performed on our Portal.

How We Collect Information

We may collect Personal Information when you voluntarily provide such information to us through the Portal, or by other communication, for example, by creating a user account, subscribing to receive emails from us, making online payments to Envita, submitting an order or request for services, completing an online survey, filling out an online form with comments or inquiries, or sending a data file.

We may automatically record Usage Information on our server logs that your browser transmits when you use the Portal. We may also collect Usage Information about how you access and interact with the Portal through the use of automated tracking technology, such as cookies. A cookie is a small data file that is transferred to a web browser, which enables the Portal to remember and customize your subsequent visits. You can instruct your browser to block the acceptance of cookies or to provide you with a warning prompt before you accept cookies from the Portal. If you reject cookies, the functionality of the Portal may be limited.

How We Use and Disclose Information

General Uses and Disclosures

We may use the information we collect from users of our Portal for the purposes described below.

Provision of Services

We may use and disclose your Personal and Usage Information to support the delivery of our services. For example, we may share your information with your business affiliates, contractors, customers, or other entities as requested and designated by you. We may also make such information accessible to third-party service providers that assist us with managing our daily business operations, such as our supply chain vendors that provide disposal, transportation, and recycling support.

We also may share your information with third-party service providers that assist Envita with hosting and maintaining the Portal, processing online payments, and otherwise facilitating e-commerce, and marketing our services. For example, we may use third parties such as Salesforce, Hubspot, and Google for these purposes. Please be aware that these third parties’ use of your information will be subject to their privacy policies or other terms, as applicable.

Contacting You

We may use your information to directly contact you in response to your inquiries; inform you about Envita’s publications, products, and services; and email you newsletters, reports, and notifications to which you subscribe. We may also use your information to communicate with your company’s Envita user account administrator regarding your account and our services.

Improving our Services

We may use your information to enhance our understanding of our users’ preferences and improve our services accordingly. Further, we may analyze Usage Information to better understand our users’ preferences with respect to the Portal’s contents and functionalities. We may also rely on Usage Information to provide you with tailored content and troubleshooting support.

Reporting to Regulators

We may share your Personal or Usage Information with state or federal regulators, such as the Indiana Department of Environmental Management and the U.S. Environmental Protection Agency, when required to do so by law.

Law Enforcement, Safety, and Legal Processes

We may share your Personal Information and/or Usage Information with law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity. We may also disclose your Personal Information and/or Usage Information if required or permitted to do so by law; for fraud protection and credit risk reduction purposes, or in the good-faith belief that such action is necessary to protect and defend the rights or property of Envita or the Portal users; and to act under urgent circumstances to protect the safety of Envita or its employees or a member of the public. We may also disclose your information to comply with a judicial proceeding, court order, subpoena, or legal process.

Sale or Acquisition of Assets

If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if our services are transferred to another company, we may disclose and/or transfer your Personal Information and/or Usage Information as part of the transaction. If we are not the surviving entity in that transaction, the surviving entity may use your Personal Information and/or Usage Information pursuant to its own privacy policies and practices, which may differ from this Privacy Policy.

Security of Personal Information

Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be 100 percent secure. As a result, while we attempt to protect all Personal Information, we cannot ensure or warrant that Personal Information will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network. We will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable state and federal laws) stored by or for us. By disclosing your email address to us for any reason, you expressly consent to receive electronic notice from us in the event of such a security breach.

Children’s Privacy

The Portal is not intended for use by a child under the age of 13. We do not knowingly collect any Personal Information from a child under the age of 13 through the Portal. If you are aware of a child under the age of 13 using the Portal, please alert us at the contact information listed below.

Other Provisions

Third-Party Links

The Portal may contain links to websites not affiliated with us. Your use of an external website or any informational content found on an external website is subject to and governed by the privacy policies, terms, and conditions of that website. We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on an external website, even if one or more pages of the external website are framed within a page of our Portal. We are not responsible for the privacy practices of any external website.

Online Payments

We use a third-party e-commerce vendor to collect and process your payments for any products and services you purchase using the Portal. Accordingly, Envita does not store your payment card information or financial account information. The information you provide when you make a purchase using the Portal will be subject to the vendor’s privacy policy, as well as any agreements between Envita and the vendor.

Accessing and Updating Information

If you would like to access, update, delete, or modify Personal Information, you may do so through your Portal user account. You may reach us at the contact information listed below if you need assistance or would like to delete your user account. Modifying, updating, or deleting any information will not result in the modification, updating, or deletion of any such information that may reside in back-up or disaster-recovery storage.

Opting Out

If you would like to opt out of receiving email communications from us, you may do so by changing your subscription settings through your Portal user account or contacting us at the contact information listed below.

Your California Privacy Rights

California law provides that California residents have a right to request businesses to tell them how their personal information has been shared, if at all, with third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at the contact information listed below.

Do Not Track

Certain web browsers and other devices you may use to access the Portal may permit you to submit your preference that you do not wish to be “tracked” online. We do not currently commit to responding to these submissions, in part, because no common industry standard for “do not track” has been adopted by industry groups, technology companies, or regulators. We will make efforts to monitor developments around Do Not Track browser technology and the implementation of a standard.

Google Analytics and AdWords

We may share your Usage Information with Google Analytics, a web analysis service provided by Google. Google Analytics plants a cookie on your web browser to identify you as a unique user each time you visit the Portal, but the cookie cannot be used by anyone but Google.

We may also use Google AdWords to deliver tailored advertising of our products and services based on users’ past visits to the Portal. This allows Google to place our advertisements on websites and mobile apps that are unaffiliated with Envita, and users may access these advertisements using multiple devices. This Privacy Policy does not cover the privacy practices of the third-party websites and apps on which our advertisements may be placed.

Some Portal users may have permitted Google to both link their web and app browsing histories with their Google accounts and use their Google account information to offer personalized advertisements. Google collects identifiers associated with such Portal users’ Google accounts and combines them with other Google Analytics information to optimize the delivery of personalized advertisements across various user devices.

Google’s ability to use and share information about your visits to the Portal is restricted by the Google Analytics Terms of Use and Google’s Privacy Policy. You may prevent Google Analytics from recognizing your future visits to the Portal by disabling cookies on your browser or installing Google Analytics’ opt-out browser add-on. You may control your experience with advertisements or opt out of receiving personalized advertisements altogether by visiting Google’s Ad Settings.

Updates to the Privacy Policy

We may periodically revise the Privacy Policy in our sole and absolute discretion to reflect changes in the law or our business practices. If we revise the Privacy Policy, we will notify you by posting the updated Privacy Policy on our Portal. Changes to the Privacy Policy will become effective and will apply to the information collected starting on the date we post the revised Privacy Policy on our Portal. Your continued use of the Portal after any change to our Privacy Policy has become effective will constitute your acceptance of the change.

Comments and Questions

If you have a comment, question, or requested related to the Privacy Policy, please reach us by email at legal@heritage-enviro.com or by calling 317-334-2300.

 

C\1196632.1