We may modify this Policy at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you.
If you use this Site, you must comply with our Term of Use (“Terms”) found [insert link].
Categories of Personal Information We Collect
We may collect the following categories of Personal Information, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”):
- Identifiers. Identifiers such as: a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, or other similar identifiers.
- Internet Activity. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Employment Information. Professional or employment-related information that may be collected by or otherwise shared with our third-party providers that track, store, and process information associated with job applications. To the extent that you disclose Personal Information to any third parties, different rules may apply to their use and disclosure of Personal Information that you disclose to them. We encourage you to review the privacy policies of all other websites before disclosing your Personal Information to them.
This Policy does not apply to any information that is publicly available.
Categories of Sources
We may collect all categories of Personal Information listed above from the following categories of sources:
SOURCE 1: We Collect Personal Information Directly From You.
We collect Personal Information that you provide directly to us. Personal Information is required to use certain Site features, for example, to contact us via email, phone, or our Contact Us form (where we may retain your message’s content and our response), submit job application materials, receive or request data from us (e.g., catalogs and newsletters), and respond to communications from us.
Feedback. When you provide comments or feedback about our Site, the content on the Site, or our products or services (“Feedback”), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
Business Contracts with Us. When a business contracts directly with us for the purchase of our products or services, we may collect the business contact information of those involved. The processing of any information provided in such a business context is governed by the contracts between that business and Dixon Ticonderoga.
SOURCE 2: We Collect Personal Information Automatically.
We automatically collect certain information from you when you access our Site.
Cookies & Other Tracking Technologies.
What types of online tracking mechanisms do we use?
What are cookies and web beacons/pixel tags?
A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser. Web beacons/pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
Why do we collect Cookies?
- make our Site function properly;
- provide personalized experiences;
- tailor our interactions with you;
- help with our marketing efforts;
- provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and
- help us improve our services
What type of information do Cookies collect?
The Cookies on our Site may collect information such as:
- IP addresses assigned to the computers and other devices you use;
- your internet service provider;
- device ID number;
- approximate geographic location;
- the Site pages visited or clicked on;
- the date and time you visited the Site, and the amount of time spent on the Site;
- your operating system, browser type, search requests, and other similar information;
- websites you access before and after visiting the Site, and
- data related to how and when you use the Site.
We may combine information from Cookies with Personal Information, including data obtained from other sources.
How long do Cookies last?
A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
Flash cookies differ from other browser cookies regarding the amount and types of data collected and how the data is stored. Your browser will not remove and cannot manage Flash cookies in the same way as other Cookies. To learn about managing your Flash cookie settings, visit the Flash player settings page on Adobe’s website here.
We are not responsible for third-party Cookies.
Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We do not have control over how information gathered by third-party Cookies is used by third parties.
How do you manage Cookies or opt-out?
Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.
California’s “Do-Not-Track” Requirement. we currently do not honor “do not track” requests.
Google Analytics. We use Google Analytics to collect and process information about your use of the Site. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site.
We may also implement additional add-on services to Google Analytics, such as [insert a list of the Google modules used – listing the add-on services used is required by the Google Terms of Service]
Online Behavioral Advertising. We use third parties and/or service providers to provide internet-based advertising services. These services collect data about your interactions with the Site and other websites to send you targeted advertisements for goods and services. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites and may be sent to you via email.
To change your preferences with respect to certain online ads and to obtain more information about online ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads.
Purpose for Collecting Personal Information
We may use all categories of Personal Information listed above for the following business purposes:
As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.
Administration. We use Personal Information for administrative purposes, such as to understand the Site’s demographics and user preferences and for evaluating job applications.
Site Management. We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.
To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to address any DMCA claims or counterclaims [delete if N/A] to seek business, financial or legal advice, and to respond to other legal requests.
Categories of Third Parties and/or Services Providers With Whom We Share Personal Information
We may share all categories of Personal Information listed above with the following categories of third parties and/or service providers:
Employees and Affiliates. We may share Personal Information with our employees and affiliates who have a need to know the information for our business purposes.
Third-Parties and/or Service Providers. We may share Personal Information with third parties and/or service providers that provide services for us, with whom we have contracted with to protect such Personal Information. For example, we may share Personal Information with vendors to help us host and manage the Site; provide and host the job portal; improve the content and functionality of the Site; perform data analysis and statistical analysis; troubleshoot problems with the Site; provide public relations; provide learning management systems; provide email services; provide data processing; and support or provide the security of the Site.
Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Dixon Ticonderoga or any other party.
Professional Advisors. We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Dixon Ticonderoga.
Other Users. By submitting a copyright infringement notice, counter-notice or other similar notification, you consent to having that communication forwarded to any person or entity to whom the notice or counter-notice relates to, in order to facilitate a prompt resolution of the copyright infringement claim. Copyright infringement notices and/or counter-notices from you will be treated in accordance with our DMCA Policy found at: [insert link] (“DMCA Policy”).
Change in Ownership. In the event (a) Dixon Ticonderoga is the subject of a change of control (including as part of the due diligence process), (b) the Site changes ownership, in whole or in part, or (c) of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s).
Other. We may share Personal Information with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Categories of Personal Information Sold [OR] We do not Sell Personal Information
[choose which one applies and update accordingly]
In the last 12 months we have not Sold your Personal Information and we currently do not Sell Personal Information. “Sold” / “Sell” has the definition set forth in the CCPA.
In the last 12 months we Sold the following categories of Personal Information. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category.
- Category A: Identifiers
- Category B: Internet Activity
- Category C: Employment Information
We Have Not Disclosed Personal Information for a Business Purposes
In the last 12 months we have not disclosed your Personal Information for a Business Purpose. “Business Purpose” has the definition set forth in the CCPA.
Use and Disclosure of De-Identified or Aggregated Information
Dixon Ticonderoga may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Dixon Ticonderoga is the sole and exclusive owner of such de-identified and aggregated information, including if Dixon Ticonderoga de-identifies Personal Information so that it is no longer considered Personal Information under applicable laws.
The Site is not directed at children under 16 years of age. We do not knowingly collect, use, or share Personal Information from children under 16. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.
For clarity, to our knowledge, we do not sell the Personal Information of anyone under the age of 16 years old without affirmative authorization.
Your Rights to Access and Deletion
Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, you may exercise the following rights with regard to your Personal Information:
Right to Access. You have a right to access any of the following which occurred in the prior 12-month period: (a) the categories of Personal Information we collected from you, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for collecting or selling your Personal Information, (d) the categories of third parties with whom we shared your Personal Information, (e) the specific pieces of Personal Information we collected from you (i.e. “data portability”), and (f) if applicable, a list of categories of Personal Information we Sold or disclosed for a Business Purpose in the last 12 months.
Right to Deletion. You have a right to request that we delete Personal Information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
How to Exercise Your Rights of Access and Deletion
How to Exercise Your Rights. To exercise your rights described in this Policy, you may submit your request to us by contacting us at any of the following:
[INSERT TOLL-FREE NUMBER]
[email; mail, phone, etc.]
More on Submitting a Request to Delete. You may submit your request to delete here: [insert a link to the online request form or portal].
Verifiable Consumer Request. In order to verify your request, you must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information and you must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
When We Will Respond. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Your Rights to Opt-Out of the Sale of Personal Information
You may direct us not to sell your Personal Information at any time (this is your right to “opt-out”). You may submit your opt-out request by following this link: [insert the “DO NOT SELL MY PERSONAL INFORMATION” button described in the proposed regulations]
To opt-out online, please use the following web-form: [insert link]. Other ways you may opt-out include: [insert].
You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this Section.
Who May Exercise Your Rights?
You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) provide signed, written permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with Dixon Ticonderoga, and (c) directly confirm with Dixon Ticonderoga that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.
We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.
Furthermore, a parent or legal guardian may make a request on behalf of their child.
Shine the Light
Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” Section below.
While Dixon Ticonderoga is not directly active on social media, other websites maintained, owned or controlled by us are active on Facebook and Instagram (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages.
Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
Anything you post on Social Media is public information. YOU AGREE TO HOLD DIXON TICONDEROGA AND ITS AFFILIATES HARMLESS AND WITHOUT LIABILITY FOR THE RESULTS OF ANY AND ALL CONTENT YOU POST TO VISIT MILWAUKEE’S SOCIAL MEDIA PAGES.
The website may also use the advertising services and networks offered by those Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you are accessing the website.
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.
no data transmission over the internet or device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk.
Access from Outside the United States
If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by other jurisdictions.
If you have any questions you may contact us as set forth below:
[Attn: insert name or / department or / title]
[Toll-free phone number]