January 1, 2020
This is the Privacy Statement of UFP Industries, Inc. and our affiliates (the "Company," "us", "we", or “our”). Please see the section below that identifies our affiliates.
Our Commitment to Privacy
We are committed to your privacy. We want you to be familiar with how we collect, use and disclose your information. This Privacy Statement is intended to comply with U.S. and international data protection and privacy laws, including the EU General Data Protection Regulation, and describes our practices in connection with information that we collect online and offline.
What Information We Collect
“Personal Information” is information that identifies you as a natural person or relates to an identifiable natural person. We may collect and process the following Personal Information:
- Personal contact information such as name, address, telephone number and email address;
- Business contact information such as business address, telephone number and email address;
- Information necessary to provide products and services to you or your organization;
- Instructions, comments, and opinions you provide when you contact us directly by email, chat, direct messages, online forms, telephone, or mail;
- Your opinions via surveys we send to you regarding current services, potential new services that may be offered, our Websites, or other matters;
- Payment, credit, and transaction information for billing purposes (however, we do not collect or retain any of your credit or debit card information as a third party service provider processes your financial information);
- Purchase history;
- IP addresses;
- Information that you choose to provide to us when you interact with us or our service providers; and
- Employment related information if you are an employee or former employee of the Company or are applying for a job with us.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. We may collect and process the following Other Information:
- Browser and device information;
- App usage data;
- Information collected through cookies, pixel tags and other technologies;
- Demographic information and other information provided by you that does not reveal your specific identity; and
- Information that has been deidentified or aggregated in a manner such that it no longer reveals your specific identity.
If we are required to treat Other Information as Personal Information under applicable law, then we will collect, use and disclose it for the purposes for which we collect, use and disclose Personal Information as detailed in this Privacy Statement. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through public message boards, conversation pages, blogs, profile pages, or other similar services, it may be publicly posted and otherwise publicly available for use.
How We Collect Personal & Other Information
We and our service providers may collect Personal Information online in a variety of ways in connection with providing our products and services. Examples include:
- Through our websites, including any chat function (“Websites”);
- Through the software applications made available by us for use on or through computers and mobile devices (“Apps”);
- Through social media properties (“Social Media”);
- Through email messages (“Emails”);
- Through extranet sites made available to our customers and third parties (“Extranet Sites”);
- Through products and services we provide to our customers; and
- Through our registration process for newsletters, seminars, webinars, certifications, events, contests, sweepstakes, or promotions.
We also may collect Personal Information offline in a variety of ways in connection with our products and services. Examples include:
- When you participate in a contractual arrangement for our products and services;
- When you provide information in conjunction with our products and services;
- When you provide information over the phone;
- When you provide information through paper-based forms, applications, and other documents;
- When you interact with us at a trade show, in connection with a sales call, or in other similar situations;
- When you participate in a contest, sweepstake, or promotion;
- When you provide information in connection with a rebate; or
- When you interact with us at a Company event, seminar, training, or clinic.
We also may collect Personal Information from other sources. Examples include:
- Publicly available databases;
- Joint marketing partners and event sponsors, when they share the information with us;
- Entities to which we provide products and services, which may include your employer; and
- Referral sources.
We need to collect Personal Information in order to provide our products and services to you. If you do not provide the information requested, we may not be able to provide our products and services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with our products and services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.
We and our service providers may collect Other Information in a variety of ways, including:
Through your browser or device:
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, device type (e.g. desktop or mobile), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version, and the name and version of the software or platforms (such as an App) you are using.
Through your use of an App:
When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Our Websites may now or in the future use "cookies" to help you personalize your online experience. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. This simplifies the process of recording your personal information, such as billing addresses and so on. When cookies are used and when you return to a Website, the information you previously provided can be retrieved, so you can easily use the Website features that you customized. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Flash cookies will need to be controlled via an online platform provided by Adobe. If you choose to decline cookies, you may not be able to fully experience the interactive features of our Websites.
Through use of web beacons:
Pages of our Websites, Apps, Emails, Social Media, and other similar communication methods may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company to transfer or collect information through a graphic image request. Web beacons can be used, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We may collect information through web beacons about your activities such as the address of the page you are visiting, the address of the referrer page you previously visited, the time you are viewing the page, your browsing environment, and your display settings.
We may use the information we collect through web beacons:
- To understand traffic patterns and the number of visitors to our network of Websites, our affiliates’ websites, and other non-Company websites with whom we partner, our Apps, and our Social Media;
- To understand how you use and interact with our products and services;
- To improve our products and services;
- To optimize and personalize your browsing experience;
- To provide anonymous individual and/or aggregate auditing, research, modeling and reporting;
- To provide you relevant advertising and content;
- To measure the effectiveness of our advertising; and
- To determine which email messages sent by us, or our agent, were opened and to note whether a message was acted upon.
Turning off your cookies will prevent web beacons from tracking your specific activity. The web beacon may still record an anonymous visit from your IP address, but unique information will not be recorded.
Through use of third party analytics:
We may use third party analytics services, such as those of Google Analytics (including Google AdWords and Google Tag Manager), Facebook Pixel, and Pinterest Tag. These services help us analyze how our Website, Apps, Social Media, and other platforms are used, and information collected as part of these services is automatically sent to the service provider. To learn more about Google Analytics and an opt-out browser add-on, please click here: https://tools.google.com/dlpage/gaoptout/.
Do Not Track
Your web browser may have a “Do Not Track” feature that is intended to automatically inform websites you visit to not track your online activities. Our Websites do not process or respond to these “Do Not Track” signals from your browser.
Your IP address is automatically assigned to your computer by your internet service provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses our Websites and Apps, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, improving our Websites and Apps, and administering the Websites and Apps. We may also derive your approximate location from your IP address.
How We Use Personal Information
We and our service providers use Personal Information for legitimate business purposes, including:
Providing products and services
- To contact individuals (including employees of corporate customers) in connection with providing our products and services;
- To respond to inquiries and fulfill requests from our customers and others, administer their file(s), and provide information on our products and services;
- To provide our products and services and to process a return; and
- To manage our relationships, including responding to a review.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Providing you with our newsletter and/or other marketing materials, facilitating social sharing, and administering and conducting promotions, trainings, and other events
- To send you our newsletters, publications, legal updates, and mailings related to our seminars, events, or products and services that we think may be of interest to you;
- To fulfill your event registration requests and provide services, including the provision of seminars and other events;
- To send you information about our products and services and other news about our Company; and
- To administer your participation in a contest, sweepstake, rebate or other promotion or to send you prizes that you might have won.
We will engage in this activity with your consent or where we have a legitimate interest.
Providing the functionality of our Websites and other platforms and fulfilling your requests
- To provide our Websites’ and Apps’ functionality to you, such as arranging access to your registered account and providing you with related client service;
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise (e.g., when you send us questions, suggestions, compliments or complaints, or when you request other information about our products and services);
- To send administrative information to you, such as information regarding our products and services and changes to our terms, conditions and policies; and
- To make improvements to the Websites and Apps.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Accomplishing our business purposes
- For data analysis, for example, to improve our Websites, Apps, products, and services;
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud and security monitoring purposes (for example, to detect and prevent cyberattacks or attempts to commit identity theft);
- To meet our legal and regulatory obligations;
- For enhancing, improving, or modifying our current products and services;
- For identifying usage trends to operate and expand our business activities (for example, understanding which parts of our products and services are of most interest to users); and
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
How We Disclose Personal Information
We disclose Personal Information:
To our affiliates for the purposes described in this Privacy Statement
- You can consult the list and location of our affiliates listed below. Subject to local requirements, this information may be used to provide products and services offered by our other legal entities and for all the purposes outlined in this Privacy Statement.
- UFP Industries, Inc. is the party responsible for the management of the jointly-used Personal Information.
To our third party service providers and trusted business partners to facilitate services they provide to us
- These can include providers of services such as website hosting, products and services-related consulting and monitoring, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, fulfill orders you have placed, or fulfill the purpose for which you have provided it (such as for contests or promotions) and other services.
- All such third parties are prohibited from using your personal information except to provide these services to the Company, and they are required to maintain the confidentiality of your information.
To public authorities in response to lawful requests by public authorities to comply with national security or law enforcement requirements.
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations, including laws outside your country of residence;
- To cooperate with public and government authorities, including authorities outside your country of residence;
- To cooperate with law enforcement;
- For other legal reasons, such as to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
- In connection with a sale, merger or business transaction.
We do not sell, rent, or lease Personal Information to third parties.
How We Use Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.
How Long We Retain Personal Information
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide our products and services to you (for example, for as long as you have an account with us or keep using our products and services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions or communications for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
What Security Measures We Use
While no data security program can fully prevent the unauthorized access to, loss of, accidental destruction of, misuse of, or disclosure of Personal Information, we have implemented internal policies and technical measures to protect Personal Information from loss, accidental destruction, misuse or disclosure. Such internal policies and technical measures include:
- The use of pseudonymization and encryption of personal data where appropriate;
- Procedures and controls to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- Procedures and controls to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
- Procedures for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing;
- Procedures to ensure that data is not accessed, except by individuals in the proper performance of their duties;
- The use of contractual language requiring our service providers and other third parties to whom we disclose Personal Information to comply with applicable data privacy laws and to protect the confidentiality of the information; and
- Training all of our employees who handle Personal Information on how to properly handle and protect Personal Information.
Your Choices Regarding Marketing-Based Communications
If you supply us with your address (mailing or e-mail), you may receive periodic mailings from us or our affiliates with information on new products and services, upcoming events, and other industry-related news. We will comply with all legal requirements to obtain your consent for such mailings. If you do not wish to receive such mailings (whether by e-mail or paper mail), please let us know by e-mailing us at firstname.lastname@example.org with the word "unsubscribe" in the subject line. Please provide us with your exact name, mailing address, and e-mail address.
If you supply us with your mobile telephone number and opt into our SMS program, you may receive text messages from us or our affiliates with information regarding new products and services or upcoming events. If you do not wish to receive such text messages, please let us know by sending us a text with the word "STOP" in the subject line.
With the data we have collected on your activities on our Websites, Apps, Social Media or through other interactions with us, we may, with your consent or pursuant to our legitimate business interests, provide advertising of our products and services personalized to your individual interests, and we may share such information with third party vendors in order to advertise our products and services to you. We may also work with online advertising vendors to provide you with ads of our products and services that you may find relevant. These ads may appear on our Websites, on the websites of third parties, our Apps, or our Social Media. In addition, these ads may be based upon information collected by us or third parties.
To opt out of personalized advertising, you may be able to adjust settings on your browser or on your mobile device. Please see the documentation associated with your browser and mobile device for more information. In addition, the Digital Advertising Alliance provides information on how to opt out of personalized advertising; for more information, please click here: http://optout.aboutads.info/?c=2&lang=EN.
Privacy Rights for California Residents and Users
Individual California Users may request information about our disclosures of certain categories of Personal Information to third parties (i.e., our affiliates) for such third parties’ direct marketing purposes.
As noted above, we may disclose Personal Information to Company affiliates, which may use this information for all purposes outlined in this Privacy Statement. Because separate legal entities are considered “third parties” for purposes of California Civil Code Section 1798.83, and certain communications from our affiliates might be viewed as promoting their products and services, we are providing the following information for California residents who have provided us with their Personal Information during the creation of or during the course of an established business relationship that is primarily for personal, family, or household purposes (“Individual California Users”).
We will provide a list of the categories of Personal Information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.
Individual California Users must submit their requests to us either by email at email@example.com or write us at: 2801 East Beltline Ave. NE, Grand Rapids, MI 49525, Attn: Privacy.
[CCPA Requirements Effective January 1, 2020]
If you are a California resident, you have the following additional rights under the California Consumer Privacy Act (CCPA) regarding your Personal Information we hold:
- You have the right to obtain confirmation of whether, and where, we are processing your Personal Information, information about the categories of Personal Information we are processing, and a copy of the Personal Information we hold about you.
- Right to receive our products and services on equal terms regardless of whether or not you exercise your rights under the CCPA.
- You have the right, in some circumstances, to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified.
- While we do not sell your Personal Information to third parties, you have the right to direct us not to sell your Personal information by clicking this DO NOT SELL MY PERSONAL INFORMATION LINK or by calling us at this toll-free hotline: 1-855-435-3935.
Privacy Rights for Nevada Residents and Users (effective October 1, 2019)
If you are a Nevada resident, you have the following additional privacy rights regarding your Personal Information we hold:
- While we do not sell your Personal Information to third parties, you have the right to direct us not to sell your Personal information by emailing your verified request to: firstname.lastname@example.org.
Privacy Rights for Residents of the European Economic Area and Switzerland
If you are resident in the European Economic Area or Switzerland, under European or Swiss law you have the following additional rights in respect of your Personal Information that we hold:
- Right of access: You have the right to obtain confirmation of whether, and where, we are processing your Personal Information; information about the categories of Personal Information we are processing; the purposes for which we process your Personal Information; information as to how we determine applicable retention periods; information about the categories of recipients with whom we may share your Personal Information; and a copy of the Personal Information we hold about you.
- Right of portability: You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use or to request the transfer of your personal data to another person.
- Right to rectification: You have the right to obtain rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay.
- Right to erasure: You have the right, in some circumstances, to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified.
- Right to restriction: You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by you.
- Right to object: You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
- If you are resident in France, you also have the right to set guidelines for the retention and communication of your Personal Information after your death.
If you wish to exercise one of these rights, please contact us at email@example.com.
EU residents also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Swiss residents have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner at: https://www.edoeb.admin.ch/?lang=en.
Residents in other jurisdictions may also have similar rights to the above. Please contact us at firstname.lastname@example.org if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.
Children’s Privacy Statement
Our products and services are not intended for those under the age of 18, and we will not knowingly collect Personal Information from such individuals under the age of 18.
Privacy Rights for Applicants and Employees
We have privacy polices specific to employment matters, including applicants. Please contact us at email@example.com if you are an applicant or employee and would like more information about our privacy policies for employment matters.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using our Website, Apps, Social Media, products and services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information. We comply with all data privacy laws whenever Personal Information is transferred across borders.
For Personal Information transferred from the EEA and Switzerland, we make sure that the data is transferred either: (1) to countries that are recognized by the European Commission and Switzerland as providing an adequate level of data protection according to EEA or Swiss standards or (2) pursuant to legally compliant methods, such as standard contractual clauses adopted by the European Commission or contracts approved by the Swiss Commissioner, to protect your Personal Information.
For Personal Information transferred from other countries with data protection and privacy laws, we make sure that the information is transferred pursuant to that country’s legal requirements.
Third Party Services
This Privacy Statement does not address, and we are not responsible for, the privacy, information or other practices of any third parties.
This includes any third party operating any website or service to which our Websites, Apps, or Social Media link. The inclusion of a link on our Websites, Apps, or Social Media does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media.
For purposes of this Privacy Statement, the entities listed in Exhibit 21 to our Annual Reports are considered to be “affiliates” of UFP Industries, Inc. Please see the most current listing here: http://www.ufpinvestor.com/financial-information/annual-reports.
Changes to this Privacy Statement
We will occasionally update this Privacy Statement to reflect current Company policies. If this Privacy Statement is revised, the revised Privacy Statement will be posted here with the date of the most recent version posted above. Continued use of our Websites, Apps, or Social Media after any such revision or update constitutes your acceptance of the Privacy Statement as so revised or modified. We encourage you to periodically review this Privacy Statement to be informed of how the Company is protecting your information. Finally, the terms of this Privacy Statement are subject to all applicable laws, rules, and regulations.
Not a Contract
This Privacy Statement is not a contract but is intended to comply with applicable data privacy laws.
We welcome your comments regarding this Privacy Statement. If you believe that we have not adhered to this Privacy Statement or if you have any other questions, please feel free to contact us:
UFP Industries, Inc.
Copyright ã 2020 UFP Industries, Inc. All Rights Reserved.