Last updated June 2018
(“Picarro”) operates the Picarro website and Picarro Community online forum
(collectively with all content, services and products available on or through
the website, the “Website”). It is Picarro’s policy to respect your privacy
regarding any information we may collect while operating the Website.
information we collect about you
How we use information we collect
How we share
information we collect
How we store
and secure information we collect
How we transfer information we collect internationally
How to access
and control your information
important privacy information
For the purposes of
the General Data Protection Regulation of the European Union (the “GDPR”),
Picarro is the Data Controller with respect to information collected through the
Website. Picarro’s contact information can be found in the “Contact Us” section
Website and Community Visitors
Like most website
operators, Picarro collects non-personally-identifying information of the sort
that web browsers and servers typically make available, such as the browser
type, language preference, referring site, and the date and time of each
visitor request. Picarro’s purpose in collecting non-personally-identifying
information is to better understand how Picarro’s visitors use the Website. We
may choose to aggregate this non-personally-identifying information with your
personal data for analytics and other purposes.
The Website is not
intended for or directed to persons under the age of 16, and we will not
knowingly collect information from such persons. Any person who provides
information to us through registration or in any other manner on the Website
represents to Picarro that they are 16 years of age or older. If we learn that
a child under 16 has submitted personal data to us, we will attempt to delete
the information as soon as possible.
Gathering of Personal Data
Certain visitors to
the Website choose to interact with Picarro in ways that require Picarro to
gather personal data that allows them to be individually identified. We may collect, use, store and transfer
different kinds of personal data about you which we have grouped together as
Data includes first name,
last name, username or similar identifier, professional title, and employer.
Data includes billing
address, delivery address, email address and telephone numbers.
Data includes bank account
and payment card details.
Data includes details about
payments to and from you and other details of products and services you have
purchased from us.
Data includes internet
protocol (IP) address, your login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and
platform and other technology on the devices you use to access our Website.
Data includes your
username and password, purchases or orders made by you, your interests,
preferences, feedback and survey responses.
Data includes information
about how you use our Website, products, and services.
and Communications Data includes
your preferences in receiving marketing from us and, where relevant, third
parties acting on our behalf, and your communication preferences.
The amount and type of
information that Picarro gathers depends on the nature of the interaction. For
example, we ask visitors who sign up for the Picarro Community to provide a
username, email address, geographic location, and other information including
main area of specialty and name of employer. Picarro may ask for payment
information, including credit card information, in connection with purchases
made on the Website. All credit card
information submitted through the site is processed by a third party provider
on Picarro’s behalf and cannot be accessed by Picarro. In each case, Picarro collects such
information only as far as is necessary or appropriate to fulfill the purpose
of the visitor’s interaction with Picarro. Picarro does not disclose personal
data other than as described below. Visitors
can always refuse to supply personal data (except to the extent a user’s IP
address or other Technical Data supplied by their device may constitute
personal data), with the caveat that it may prevent them from engaging in
certain Website-related activities. Picarro will only use your personal data,
including your contact details, for marketing purposes if doing so is within
the scope of our legitimate interests, you have given your explicit consent for
us to do so, or we have an existing business relationship with you. Picarro
will never sell, rent, or provide user information to other vendors or other
companies that seek to market or sell products by using such user information.
We do not collect any special
categories of Personal Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership or information about
your health and genetic and biometric data). Nor do we collect any information
about criminal convictions and offenses.
Picarro may collect statistics about the
behavior of visitors to our Website. For instance, Picarro may monitor the most
popular content on the Website or report the most popular discussion groups in
the Picarro Community. However, Picarro does not disclose personal data other
How your Personal Data is Collected
We use different methods
to collect data from and about you.
interactions. You may give us your name,
email, phone, address, and financial data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
request our products or
create an account on our Website;
subscribe to our service
request that marketing materials/information
be sent to you;
give us feedback.
technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment,
browsing actions and patterns. We collect this personal data by using cookies and
other similar technologies. Please see further information concerning our use
of cookies that is provided below.
parties or publicly available sources. We may receive personal data about you from various third parties and
publicly available sources as set out below:
Picarro may use targeted
marketing services provided by third parties to identify businesses and
institutions that may be interested in Picarro’s products and services and the
individuals who work for them. If we hold information about you that we have
collected through the Website, we may aggregate information received from third
parties with that information.
Picarro may access
publicly available information about you. For example, if you complete a web
form on Picarro’s site or request further information from Picarro, Picarro may
undertake research about you or the business or entity you work for and
aggregate that information with personal data collected through the Website.
Technical Data from the
parties identified in Exhibit A.
Disclosure and Use of Certain Personal Data
Picarro discloses personal
data to those of its employees, service providers, contractors and affiliated
organizations that (i) need to know that information in order to process it on
Picarro’s behalf or to provide services available on or through the Website,
and (ii) that have agreed not to disclose it to others. Some of those
employees, service providers, contractors and affiliated organizations may be
located outside of your home country. Please see the information concerning
international transfers set forth below regarding such employees, service
providers, contractors and affiliated organizations.
How We Use Your Personal Data and Our Legal Basis for Doing So
We will only use your personal
data as permissible by law. Most
commonly, we will use your personal data in the following circumstances:
Where we need to perform
the contract we are about to enter into or have entered into with you.
Where it is necessary for
our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override our interests.
Where we need to comply
with a legal or regulatory obligation.
Generally, we do not
rely on consent as a legal basis for processing your personal data other than
in relation to sending direct marketing communications to you via direct mail, email,
or text message where we do not have an existing business relationship or other
legitimate interest in doing so. If we do rely on consent, you have the right
to withdraw consent to marketing at any time by contacting us in the manner set
to object to our processing of your personal data in any case, again, by
We have set out below,
in a table format, a description of all the ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified
what our legitimate interests are where appropriate.
Note that we may
process your personal data on more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you
need details about the specific legal ground we are relying on to process your
personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate
To register you as a new customer
Performance of a contract with you
Necessary for our legitimate interests
(operating our business)
To process and deliver your order including:
(a) Manage payments, fees and
(b) Collect and recover money owed
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to
recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to
(b) Asking you to leave a review or
take a survey
(c) For after sales service, including
marketing and managing any
maintenance contracts, repairs to
or questions about our products
(d) Marketing and
(a) Performance of a contract with you
(b) Necessary to comply with a legal
(c) Necessary for our legitimate interests (to
keep our records updated and to study
how customers use our
To administer and protect our business and the Website
(including troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for
running our business, provision of
administration and IT services, network
security, to prevent fraud and in the
context of a business reorganization or
group restructuring exercise)
(b) Necessary to comply with a legal
To deliver relevant Website content and advertisements to you
and measure or understand the effectiveness of the advertising we serve to
(e) Marketing and
Necessary for our legitimate interests (to study how customers
use our products/services, to develop them, to grow our business and to
inform our marketing strategy)
To use data analytics to improve our Website, products/services,
marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of
customers for our products and services, to keep our Website updated and
relevant, to develop our business and to inform our marketing strategy)
To make suggestions and
recommendations to you about goods or services that may be of interest to you
for our legitimate interests (to develop our products/services and grow our
With your consent
All types of data
We may use information about you where you have given us consent
to do so for a specific purpose not listed above. For example, we may publish
testimonials or featured customer stories to promote our products/services,
with your permission.
You can ask us to stop
sending you marketing messages at any time by clicking the link at the bottom
of all marketing emails or by emailing a request to Privacy@picarro.com.
Disclosures of your Personal Data
Picarro discloses personal
data when required to do so by law, or when Picarro believes in good faith that
disclosure is reasonably necessary to protect the property or rights of
Picarro, third parties or the public at large. Additionally, Picarro may
disclose personal data in connection with a sale or merger with another entity
or if Picarro should ever file for bankruptcy or have its assets sold to
We may disclose your
personal data to our employees, contractors, or third party service partners. These third party service partners are listed at the end of this
document on Exhibit A. Some of these service partners use “cookies” or
other tracking devices on the Website, which are software programs or other
systems that collect information about your use of our services. As
described below, we will only transfer your information internationally (for
example, to information technology vendors in other countries) where we believe
appropriate safeguards are in place to protect your information.
We require all third
parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third party service providers to
use your personal data for their own purposes and only permit them to process
your personal data for specified purposes and in accordance with our
instructions. If we have an existing business relationship with you, it is
within the scope of our legitimate interests to do so, or you have expressly
consented to receive marketing communications from Picarro, Picarro may
occasionally send you emails to tell you about new features, solicit your
feedback, or keep you up to date with what’s going on with Picarro and our
products. Picarro takes all measures reasonably necessary to protect against
the unauthorized access, use, alteration, or destruction of personal data.
A cookie is a string
of information that a website stores on a visitor’s computer, and that the
visitor’s browser provides to the website each time the visitor returns.
of the Website, their Website access preferences and to maintain extended user
login sessions for a better user experience. Picarro visitors who do not wish
to have cookies placed on their computers should set their browsers to refuse
cookies before using the Website, with the drawback that certain features of
the Website may not function properly without the aid of cookies.
Our business operates
principally in the United States of America and to the extent we process your
data directly we will do so in the United States or within the European Union
or Switzerland. If you reside in the European Union, we will only transfer your
data to third parties outside of the European Economic Area ("EEA")
(a) if we have first obtained your prior consent; or (b) after taking such
measures as are necessary to ensure the transfer is in compliance with the
requirements of the GDPR. Such measures may include (without limitation)
transferring your data to a recipient in a country that the European Commission
has decided provides adequate protection for personal data, to a recipient that
has achieved binding corporate rules authorization in accordance with the GDPR,
to a recipient in the United States that has certified its compliance with the
EU-US Privacy Shield, or to a recipient that has executed standard contractual
clauses adopted or approved by the European Commission.
We have put in place
appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorized way, altered or
disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions and they
are subject to a duty of confidentiality. While we implement safeguards
designed to protect your information, no security system is impenetrable and
due to the inherent nature of the Internet, we cannot guarantee that data,
during transmission through the Internet or while stored on our systems or
otherwise in our care, is absolutely safe from intrusion by others.
We will only retain
your personal data for as long as necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal, accounting, or
reporting requirements. Without limiting the previous sentence, if we have a
business relationship with you or an entity you represent, we will retain your
personal data for at least the duration of that relationship. Otherwise, the
length of time for which we retain information will depend on the nature of the
Profile Data and Identity Data: We retain
your profile data and identity data for as long as your account is active and a
reasonable period thereafter in case you decide to re-activate your account.
Where we retain information for service improvement and development, we only
use the information to uncover collective insights about the use of our services,
not to specifically analyze personal characteristics about you.
Information you share on the Picarro Community: If your
account is deactivated or disabled, some of your information and the content
you have provided will remain in order to allow other users to make full use of
the Picarro Community. For example, we may continue to display content you
provided such as posts or responses.
Marketing information: If you have
elected to receive marketing communications from us, we retain information
about your marketing preferences for a reasonable period of time from the date
you last expressed interest in our services, such as when you last opened an
email from us. We retain information derived from cookies and other tracking
technologies for a reasonable period of time from the date such information was
Links to Third Party Sites
The Website may include links that direct you to other websites or
services whose privacy practices may diﬀer from ours. If you submit information
to any of those third party sites, your information is governed by their
privacy policies, not this one. We encourage you to carefully read the privacy
policy of any website you visit.
Your Legal Rights
You have certain choices available to you when it comes to your
information. Below is a summary of those choices, how to exercise them and some
You have the right to request a copy of your information, to
object to our use of your information (including for marketing purposes), to
request the deletion or restriction of your information, to request your
information in a structured, electronic format, the right to have your personal
data rectified if it is incorrect, the right to withdraw your consent to
processing of your personal data (where the consent is the lawful basis for
such processing) and, if the GDPR applies, the right to lodge a complaint with
a supervisory authority, which may be the Data Protection Authority in the
country where you reside.
exercise some of the choices by accessing the Picarro Community or the Website
and using settings available within your account. Otherwise, you can contact us
to exercise your rights using the contact information below.
opt out of receiving marketing communications and automated messages from us by
using the unsubscribe link within each email or by contacting us to have your
contact information removed from all promotional and transactional emails.
However, even after you opt out from receiving promotional messages from us,
you will continue to receive certain transactional messages from us regarding
our products and services such as payment failure notices or account suspension
notices sent via email.
Please email, call or write us for any
requests or questions:
Patrick Henry Drive
Clara, CA 95054
To protect your
privacy and security, we will take reasonable steps to help verify your
identity before granting access or making corrections.
By using our Website, you
recent update of this document will always be displayed at the beginning of
this page. Picarro encourages visitors to frequently check this page for any
however, where we feel it is necessary and appropriate, we may also email you
Third Party Processors/Subprocessors of Your
To support the Website and the Picarro
Community, we use diﬀerent service providers that may store and process personal
data about you. This section provides important information about the identity,
location, and role of these Data Processors/Subprocessors. We use diﬀerent
types of Processors/Subprocessors to perform various functions as explained in
the table below.
Office 365 – email servers and file storage
Amazon Web Services
Location of our Saas based managed service product, PCubed
identify returning users to Picarro Website and to analyze Website user
behavior, for example, the number of pages viewed and the duration of time
spent by a user on the Website.
anonymously track network security policies applied to visitors of the Picarro