Privacy Policy

New Privacy Policy — United States User

Effective Date: March 11, 2019

To download and/or print this Privacy Policy (“Privacy Policy”), click here.

Contents

1. INFORMATION WE COLLECT
   1. Information about You that You Provide.
   2. Information Collected Automatically.
   3. Information Zekelman Industries Collects From Other Sources.
2. HOW WE USE THE INFORMATION WE OBTAIN.
3. INFORMATION WE SHARE WITH THIRD PARTIES.
4. SWEEPSTAKES, CONTESTS, AND PROMOTIONS.
5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.
6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.
7. DATA SECURITY AND MONITORING.
8. INTERNATIONAL TRANSFER.
9. CHILDREN’S PRIVACY.
10. ACCESSING AND CHANGING INFORMATION.
11. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS.
    1. Tracking Technologies Generally.
    2. Analytics and Advertising Tracking Technologies.
    3. Communications.
12. YOUR CALIFORNIA PRIVACY RIGHTS.
13. CHANGES TO THIS PRIVACY POLICY.
14. CONTACT ZEKELMAN INDUSTRIES.

1. INFORMATION WE COLLECT

1. Information about You that You Provide.
   • Zekelman Industries, and/or its Service Providers (defined below), may collect information you provide directly to Zekelman Industries and/or its Service Providers via the Service. For example, Zekelman Industries collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here.Information Zekelman Industries, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number (“Personal Information”); and (2) demographic information, such as your zip code, recent and upcoming purchases, company name, and job title (“Demographic Information”). Except to the extent required by applicable law, Demographic Information is “non-Personal Information” (i.e., data that is not Personal Information under this Privacy Policy). In addition, Personal Information, including, without limitation, Zekelman Industries-Collected PI (defined below), once “De-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements including through anonymization, pseudonymization, and/or hashing) is also non-Personal Information and may be used and shared without obligation to you, except as prohibited by applicable law. However, we do not make assurances that De-identified data is not capable of re-identification. To the extent any non-Personal Information is combined by or on behalf of Zekelman Industries with Personal Information Zekelman Industries itself collects directly from you on the Service (“Zekelman Industries-Collected PI”), Zekelman Industries will treat the combined data as Zekelman Industries-Collected PI under this Privacy Policy.EEOC / Affirmative Action Reporting. In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
2. Information Collected Automatically.
   • Zekelman Industries, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Zekelman Industries with Zekelman Industries-Collected PI, Zekelman Industries does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or Zekelman Industries-Collected PI. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.The methods that may be used on the Service to collect Usage Information include:
     • Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
     • Information Collected by Cookies and Other Tracking Technologies:Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
       • Cookies:
         A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Service may associate some or all of these types of cookies with your devices.
       • Web Beacons (“Tracking Pixels”):
         Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
       • Embedded Scripts:
         An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Zekelman Industries’ web server, or from a third party with which Zekelman Industries works, and is active only while you are connected to the Service, and deleted or deactivated thereafter.
       • Location-identifying Technologies:
         GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked for purposes such as real time pricing and inventory information based on location.
       • Device Recognition Technologies:
         Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
       • Video Viewing:
         We may target and track the videos you view on the Service. You consent to our tracking of your video viewing through the Service or third-party social media for up to two years or as permitted by applicable law.
3. Information Zekelman Industries Collects From Other Sources.
   • Zekelman Industries may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Zekelman Industries-Collected PI. Notwithstanding anything to the contrary, except to the extent such data combined by or on behalf of Zekelman Industries with Zekelman Industries-Collected PI, this Privacy Policy is not intended to limit Zekelman Industries’ activities regarding such third-party-sourced, or non-Service-sourced, information (including Personal Information), and such data will only be treated as Zekelman Industries-collected PI to the extent it is combined with Zekelman Industries-collected PI. Zekelman Industries is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.

2. HOW WE USE THE INFORMATION WE OBTAIN.

Zekelman Industries may use information about you, including Zekelman Industries-Collected PI and other Personal Information, for any purposes not inconsistent with Zekelman Industries’ statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:

• Allow you to participate in the features we offer on the Service;
• Facilitate, manage, personalize, and improve your online experience;
• Process your registration, manage your account and/or upload your User Generated Content (“UGC”). (For more information on how UGC is treated under the Service’s Terms of Use. For more on the public nature of UGC, see Section 5);
• Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
• Zekelman Industries Affiliates’ marketing and other purposes;
• Improve the Service and for any other internal business purposes;
• Tailor our content, advertisements, and offers;
• Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so;
• Determine your location and manage digital content rights (e.g., territory restrictions); and
• Prevent and address fraud, breach of policies or terms, and threats or harm.

3. INFORMATION WE SHARE WITH THIRD PARTIES.

Zekelman Industries may share non-Personal Information, and Personal Information that is not deemed Zekelman Industries-Collected PI hereunder (provided that Zekelman Industries is aware of no restrictions of Zekelman Industries’ use, if any), with third parties or other Zekelman Industries companies, including business divisions such as Wheatland Tube and Atlas Tube (the “Zekelman Industries Affiliates”) for any purpose.

Without limiting the generality of the foregoing, we and third parties may convert your Personal Information, including Zekelman Industries-Collected PI, to non-Personal Information, including without limitation through hashing it or substituting a unique identifier for the Personal Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third party activities are subject to their privacy policies and practices. Zekelman Industries’ sharing of Zekelman Industries-Collected PI is, however, subject to the following:

• Marketing: Subject to your communications choices explained in Section 11.c, and the rights of California residents explained here, we may use your Personal Information to send you marketing communications. Absent your consent (which may be by means of opt-in, your election not to opt-out, or a third party interaction described in the next bullet point), however, Zekelman Industries will not share your Zekelman Industries-Collected PI with third parties, other than Zekelman Industries Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).
• Your Disclosure or Consent: As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Service may, by their nature, result in the sharing of your Zekelman Industries-collected Personal Information (as well as your other Personal Information and your non-Personal Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third party data receipt and collection is subject to the privacy and business practices of that third party, not Zekelman Industries.

Zekelman Industries may also share any information about you (including, without limitation, Zekelman Industries-Collected PI) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation:

• Zekelman Industries’ agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to, your information, including, without limitation, Personal Information, Demographic Information, and Usage Information, in connection with their work on Zekelman Industries’ behalf, provided however, Zekelman Industries does not authorize its Service Providers to use Zekelman Industries-Collected PI provided by Zekelman Industries to the Service Providers to send you direct marketing messages other than related to Zekelman Industries and Zekelman Industries Affiliates absent your consent. For more information on choices Service Providers may offer you click here.
• To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
• If Zekelman Industries believes your actions are inconsistent with Zekelman Industries’ terms of use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Zekelman Industries, the Service or its users, or any third party.

In addition, Zekelman Industries may share your Zekelman Industries-Collected Personal Information (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Zekelman Industries assets, or transfer of all or a portion of Zekelman Industries’ business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt in data and consent; this information will not be shared with any third parties.

4. SWEEPSTAKES, CONTESTS, AND PROMOTIONS.

Zekelman Industries may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your information, including Personal Information, may be disclosed to Zekelman Industries, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.

5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.

The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Zekelman Industries. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personal Information included in UGC is not subject to Zekelman Industries’ usage or sharing limitations, or other obligations, regarding Zekelman Industries-Collected PI or other Personal Information under this Privacy Policy or otherwise, and may be used and shared by Zekelman Industries and third parties to the fullest extent not prohibited by applicable law. Zekelman Industries encourages you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Service’s Terms of Use click here. California minors should see Section 9 regarding potential removal of certain UGC they have posted on the Service.

Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Zekelman Industries relies on you to only send to people that have given you permission to do so. The recipient’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Zekelman Industries for any other marketing purpose unless Zekelman Industries obtains consent from that person. Your contact information and message may be included in the communication.

6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.

The Service may include hyperlinks to, or include on or in connection with, the Service (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). Some of these Third-Party Services may license our name and marks. When this occurs, they post their own terms and privacy policy. They, not Zekelman Industries, are responsible for such Third-Party Services’ data practices and privacy policies and you should review their privacy policies and terms of use before using those services. An example is Creative Promotional Products for purchasing products such as apparel, drinkware, and stationary (see www.zekelmanstore.com). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.

Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Zekelman Industries’ content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Zekelman Industries or other Zekelman Industries Affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Zekelman Industries and Zekelman Industries Affiliates. Also, both Zekelman Industries and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.

Zekelman Industries may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the Service (i.e., “retargeting”).

Zekelman Industries may use Google Analytics, Adobe Analytics or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help Zekelman Industries analyze Service users and how they use the Service. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage.

Except to the extent we combine information we receive from Service Providers, Third-Party Services, or other third parties with Zekelman Industries-Collected PI, in which case Zekelman Industries will treat the combined information as Zekelman Industries-Collected PI under this Privacy Policy (see Section 1.c) data obtained by Zekelman Industries from a third party, even in association with the Service, is not subject to Zekelman Industries’ limitations regarding Zekelman Industries-Collected PI under this Privacy Policy, however such data remains subject to any restrictions imposed on Zekelman Industries by the third party, if any. Otherwise, the information collected, stored, and shared by third parties remains subject to their privacy policies and practices, including whether they continue to share information with Zekelman Industries, the types of information shared, and your choices on what is visible to others on Third-Party Services.

Zekelman Industries is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.

7. DATA SECURITY AND MONITORING.

Zekelman Industries takes reasonable measures to protect Zekelman Industries-Collected PI (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Zekelman Industries does not guarantee the security of your information collected through the Service.

To help protect you and others, Zekelman Industries and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including Zekelman Industries-Collected PI and other Personal Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with the Terms of Use and this Privacy Policy; investigate violations of or enforce these documents; and otherwise to protect the rights and property of Zekelman Industries Affiliates, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.

8. INTERNATIONAL TRANSFER.

Zekelman Industries is based in the U.S. and the information Zekelman Industries and its Service Providers collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy.

9. CHILDREN’S PRIVACY.

The Service is intended for a general audience and not directed to children less than 13 years of age.

Zekelman Industries does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.

Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Zekelman Industries here, detailing where the content or information is posted and attesting that you posted it. Zekelman Industries will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that Zekelman Industries does not control.

10. ACCESSING AND CHANGING INFORMATION.

Zekelman Industries may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Zekelman Industries-Collected PI, and potentially certain other information about you (e.g., profile and account information). Zekelman Industries will make good faith efforts to make requested changes in Zekelman Industries’ then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Zekelman Industries’ databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

11. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS.

1. Tracking Technologies Generally.
   • Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Zekelman Industries currently does not alter Zekelman Industries’ practices when Zekelman Industries receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Zekelman Industries is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Zekelman Industries is not responsible for the completeness or accuracy of this tool or third party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
2. Analytics and Advertising Tracking Technologies.
   • You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled Adobe website preferences.You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Zekelman Industries supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Zekelman Industries directly engages to serve you Interest-based Advertising will do so as well, though Zekelman Industries cannot guaranty their compliance. Zekelman Industries is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
3. Communications.
   • You can opt out of receiving certain promotional communications (emails or text messaging) from Zekelman Industries at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account and (ii) for text messages, following the instructions provided in text messages from Zekelman Industries to text the word, “STOP.” Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Zekelman Industries may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Zekelman Industries’ ongoing business relations. Except in connection with Corporate Transactions, to prospectively opt-out of our sharing of your Zekelman Industries-Collected PI, other than with Zekelman Industries Affiliates, for their own direct marketing purposes, contact us here.

12. YOUR CALIFORNIA PRIVACY RIGHTS.

Zekelman Industries provides California residents with the option to opt-in or opt-out to sharing of “personal information” as defined by California’s “Shine the Light” law with third parties, other than Zekelman Industries Affiliates, for such third parties’ own direct marketing purposes. California residents may exercise that opt-out, and/or request information about Zekelman Industries’ compliance with the Shine the Light law, and obtain disclosure of third parties Zekelman Industries has shared information with in accordance with the law for their direct marketing purposes absent your choice and the categories of information shared, by contacting Zekelman Industries here or by sending a letter to Zekelman Industries at 227 West Monroe Street, Suite 2600, Chicago, IL 60606 (Attention: Legal Department) or by emailing privacy@zekelman.com. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Zekelman Industries is only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mail address.

California minors should see “Children’s Privacy” at Section 9 regarding removal of certain content they have posted.

13. CHANGES TO THIS PRIVACY POLICY.

We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not treat your previously collected Zekelman Industries-Collected PI, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

14. CONTACT ZEKELMAN INDUSTRIES.

If you have any questions about this Privacy Policy, please contact Zekelman Industries here or at 227 West Monroe Street, Suite 2600, Chicago, IL 60606 (Attention: Legal Department).