Last updated June 2018
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 follows:
• Identity Data includes first name, last name, username or similar identifier, professional title, and employer.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical 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.
• Profile Data includesyour username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website, products, and services.
• Marketing 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.
How your Personal Data is Collected
We use different methods to collect data from and about you. These include:
• Direct 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 services;
• create an account on our Website;
• subscribe to our service or publications;
• request that marketing materials/information be sent to you;
• give us feedback.
• Third 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.
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 interest
To register you as a new customer
(a) Performance of a contract with you
(b) 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
To manage our relationship with you which will include:
(a) Notifying you about changes to
(b) Asking you to leave a review or
(c) For after sales service, including
(d) Marketing and
(a) Performance of a contract with you
(b) Necessary to comply with a legal
(c) Necessary for our legitimate interests (to
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
(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 you
(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)
(f) Marketing and
Necessary for our legitimate interests (to develop our products/services and grow our business)
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 .
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 another entity.
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.
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 information. Specifically:
Your Legal Rights
Please email, call or write us for any requests or questions:
To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.