PRIVACY POLICY
Effective Date: June 15, 2022
1. INTRODUCTION
Valtir, LLC and its subsidiaries or affiliates (“Valtir,” “us,” or “we”) appreciate your visit to our website. Because your privacy is very important to us, we want you to understand our practices with regard to collecting and using your information online, and the steps we take to safeguard it. This website privacy policy (the “Privacy Policy”) provides you with information concerning Valtir’s practices and procedures as they relate to information we collect through this website. If you have additional questions or would like further information on this topic, please feel free to write to us at media@valtir.com. We may update our Privacy Policy periodically, so please check back here for the latest version of our Privacy Policy.
2. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy governs your use of www.valtir.com (the “Website” or the “Site”), and also applies to your use of interactive features, widgets, applications, content or downloads that we make available through the Website and that post this Privacy Policy (collectively referred to herein as the “Services” or this “Site”), regardless of how you access or use this Site, whether via personal computers, mobile devices or otherwise.
This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy also does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below). Our statements under this Privacy Policy cover only information collected through this Site directly by us, and not by third parties that may interact with our Services or link to this Website, including those owned or operated by Valtir, LLC or other of its affiliates.
To the extent we provide you notice on this Site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
In addition, please review our Terms of Use, which govern your use of our Services. By using our Services, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.
3. INFORMATION WE COLLECT
3.1. Information You Provide to Us
We do not collect “Personal Information” about you through this Site unless you choose to provide it to us voluntarily, such as through the “Contact Us” page or our client/customer portal. We define “Personal Information” as any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, which may include your phone number, name, address, email address, or age. If you encounter a screen or page that requests information you do not want to share with us, do not enter the information and do not proceed with that screen or page.
If you do provide us with Personal Information, we will only use it for the purpose of responding to your inquiry, and we will not sell, license, transmit or disclose this information to third parties unless (1) you expressly authorize us to do so, (2) it is necessary to allow our contractors or agents to provide services for us, (3) in order to provide our products or services to you, (4) it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, or (5) otherwise as we are required or permitted by law. We may also use the information you choose to provide to us to improve the content of this Site and our Services or to contact you for marketing purposes.
We may collect demographic information, such as information about your gender, age, marital status and education level (“Demographic Information”) through your interaction with our Services. The type of information collected will depend on how you use our Services.
The Services do not engage in the collection of Personal Information or information about your online activities over time and across third-party web sites or online services. We have not authorized any third party to collect Personal Information about your online activities over time and across different web sites when you visit this web site. Thus, this web site does not respond to web browser “do not track” track signals or other similar mechanisms.
3.2. When You Create an Account
You may choose to create an account with this Site as a customer or client. To create an account, you need to provide account data including your name, and/or email address, and a password.
3.3. Information We Collect When You Use Our Services
In addition to any Personal Information or other information that you choose to submit to us (as described above) we and our third-party service providers may use a variety of technologies that store or collect certain information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Services. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Services, we will treat it as Personal Information.
Usage Information may include:
• your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
• your Device functionality (including browser, operating system, hardware, mobile network information);
• the URL that referred you to our Services;
• the areas within our Services that you visit and your activities there, including remembering you and your preferences;
• your Device location;
• your Device characteristics; and
• certain other Device data, including the time of day, among other information.
A discussion of the types of Usage Information we collect is described in greater detail, below.
3.4. Usage Information Collected Through Use of Tracking Technologies
A. Types of Tracking Technologies We Use
We may use a variety of tracking technologies to automatically collect Usage Information, including, but not limited to, cookies, web beacons, embedded scripts, browser fingerprinting, GPS, iBeacons, and ETags (collectively “Tracking Technologies”). A cookie (or “locally shared object”) is a data file placed on your device when you visit our site. Your browser, or other software (including Adobe Flash), may allow you to reject or remove cookies, but if you do so, some features of our Services may not work properly, and we may not be able to remember your preferences the next time that you visit. We also use web server logs to collect and store information about usage of our Services. When you visit this Site from a mobile device, like a smartphone, we may also collect additional information from your device, including your location, device identifier, and information about your mobile network.
B. Purpose of Tracking Technologies
We may use Tracking Technologies for a variety of purposes, including:
i. When Strictly Necessary to Provide the Services
We may use Tracking Technologies that we consider strictly necessary to allow you to use and access this Site, including Cookies required to prevent fraudulent activity and improve security.
ii. To Assess Performance
We may use Tracking Technologies that are useful in order to assess the performance of this Site, including as part of our analytic practices or otherwise to improve the content or services offered through the Services.
iii. To Improve Functionality
We may use Tracking Technologies to offer you enhanced functionality when accessing this Site, including identifying you when you visit this Site, delivering video content, or keeping track of your specified preferences, including in terms of the presentation of content on this Site.
iv. To Deliver Relevant Content
We may use Tracking Technologies to deliver content relevant to your interests on this Site based on how you interact with this Site. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
C. Tracking Technologies Choices and Consent
For our users in the EEA and U.K., we obtain your consent to our collection of Usage Information through using Tracking Technologies by providing you with transparent information in this Privacy Policy and providing you with the opportunity to make a choice to disable Cookies as set forth above. Please note that we are not required to obtain your consent to our use of Tracking Technologies identified above that are strictly necessary. We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.
If you are located in the state of California — or jurisdictions with similar notice and opt-out laws regarding tracking technologies — we will provide you a notice at collection and information concerning your rights to opt-out of the collection of Usage Information. Please note that you cannot opt-out of Tracking Technologies that are strictly necessary.
If you are located in locations not mentioned, this section does not apply to you.
D. Third Party Tracking
Third parties may use Tracking Technologies in connection with this Site, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for these third party privacy policies or practices. You may encounter third-party Tracking Technologies in connection with use of this Site and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.
E. Do Not Track
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There currently is no consensus among industry participants as to what “Do Not Track” means in this context. Therefore, like many websites and online services, our Services do not alter its practices when it receives a “Do Not Track” signal from a Member’s or Visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
F. Disabling Tracking Features
Regular Cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some, but not all instances, can be blocked by selecting certain settings.
We use Google Analytics to analyze Site traffic and to improve our advertising efforts. To disable Google Analytics, please download the Google Analytics Opt-out browser add-on. You also have the option to opt out of Google’s use of cookies by changing your settings via Google’s advertising opt-out page.
Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies go to Adobe’s website www.adobe.com. For more information on how you can customize your browser’s Cookie setting please visit the link to your web browser below:
o Google Chrome
o Safari
o Internet Explorer
o Mozilla Firefox
Please be aware that if you disable or remove these technologies some parts of our Services may not work and that when you revisit this Site your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
4. HOW WE USE THE INFORMATION COLLECTED
4.1. In General
We may use your Personal Information, Demographic Information, and/or Usage Information that we collect about you subject to this Privacy Policy for the following purposes:
• to provide you with information or services that you have requested or agreed to receive or to provide you with marketing materials or services on behalf of us or third parties;
• to enable you to participate in a variety of the Services’ features;
• to process your registration submitted through the Services, including verifying your information is active and valid;
• to improve our Services or their functionality, or to customize your experience on this Site, or to serve you specific content that is relevant to you;
• to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services’ policies;
• for internal business purposes; and
• for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
4.2. To Develop Services, Provide Support and Improve Security
We may use your Personal Information, Demographic Information, and/or Usage Information, to conduct research and further develop our Services. In some cases, we may work with trusted third parties to perform research.
We may use Personal Information, Demographic Information, and/or Usage Information (which can include your communications to us) to investigate, respond to and resolve complaints and security issues. We may use such information to investigate violations of our Terms of Use or this Privacy Policy.
5. SHARING OF INFORMATION WITH THIRD PARTIES
We may share non-Personal Information, such as aggregated user statistics, with third parties. We do not share your Personal Information that you have provided, such as through using our “Contact Us” page or registering through our client log-in portal, with third parties for those third parties’ direct marketing purposes.
If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with third parties for certain business and/or commercial purposes. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy.
We may also share information with third parties as described below.
5.1. When Third Parties Provide Services on Our Behalf
We may use third-party vendors to perform certain services on our behalf, such as hosting this Site, designing and/or operating this Site’s features, tracking this Site’s activities and analytics, and other administrative services.
We may provide these vendors with access to your information to carry out the services they are performing for you or for us. The information may include your Personal Information and Usage Information, including Device Identifiers and data related to you and your activities.
5.2. To Protect the Rights of Valtir and Others
To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate:
i. To protect or defend the rights, safety or property of Valtir or third parties (including through the enforcement of this Policy, our Terms of Use, and other applicable agreements and policies); or
ii. To comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders).
To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, without notice to you.
5.3. In the Event of a Business Transfer
We reserve the right to disclose and transfer all such information:
i. To a subsequent owner, co-owner or operator of this Site or applicable database; or
ii. In connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.
5.4. Your California Privacy Rights
For more information on privacy rights for California residents, please see California Privacy Rights.
5.5. Transfer of Information to the United States, Your U.K. and European Union Privacy Rights
If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”) please be aware that the personal information you submit, including information provided through our Services, is being sent to a location in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By providing such personal information, you are consenting to (and represent that you have authority to consent to), the transfer of such information to the United States for the uses and purposes described in this Privacy Policy.
If you are from the EEA or the UK, upon request, free of charge, you have the right to:
• access and obtain a copy of the Personal Information we hold about you;
• obtain information about the purposes for which we process your Personal Information and the categories of Personal Information concerned;
• obtain information on the recipients or categories of recipients (including international recipients) to whom your Personal Information has been or will be disclosed;
• transfer of your personal information from us to another data controller;
• in certain circumstances, erasure, rectification, or objection to the processing of your Personal Information that we hold about you;
• lodge a complaint to the supervisory authority in your jurisdiction in respect of our collection or use of your personal information; and
• withdraw your consent to our collection, use, storage, and dissemination of your data at any time.
Please be aware that any request for withdrawal of consent above will not affect the lawfulness of personal information collected, processed, and transferred prior to the date of such withdrawal. You can exercise your right at any time by contacting us by e-mail at privacy@valtir.com.
6. CHILDREN UNDER THE AGE OF 13
We offer the Services to businesses and individuals for the manufacture, lease, or purchase of railcars, and it is not intended for use by minors, including children under the age of 13. We do not knowingly collect personal information from children under the age of thirteen (13) such that parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) would be required. If you are a child under 13 years of age, you are not permitted to use this Site and you should exit this Site immediately.
In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at privacy@valtir.com.
7. INFORMATION SECURITY
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information and Usage Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk.
To the extent permitted by applicable law, we will retain your personal information only for as long as the Company believes it is necessary to fulfill the purposes for which it was collected, including for the purpose of meeting any legal, accounting, or other reporting requirements or obligations.
8. CHANGES TO THE PRIVACY POLICY
We may add to, update, delete from or modify our Privacy Policy at any time in our sole discretion. We reserve the right, at any time and in our sole discretion, to change the Privacy Policy. We may post or display notices of changes to the Privacy Policy on this Site. Once posted, these changes to the Privacy Policy become effective immediately.
If any change that we make is not acceptable to you, promptly stop using our Services. If you continue to use our Services, doing so is your agreement to be bound by those changes. You should check back regularly and review this Privacy Policy so that you are aware of the most current rights and obligations which apply to your agreement with us. Nothing in this Privacy Policy shall be deemed to confer any third-party rights or benefits to you.
9. QUESTIONS
If you have questions about this Privacy Policy, you may contact
Valtir, LLC
Attn: Legal Department
15601 Dallas Parkway, Suite 525
Addison, TX 75001
If you send us an email to privacy@valtir.com with questions or comments about the Services, the Privacy Policy, or the Terms of Use, we will share your messages with those within our organization who are most capable of addressing the issues contained in your message. We will keep a copy of your message until we have had an opportunity to address your concerns. We may archive your message for a certain period of time or discard it, but your email address will not be used for any other purpose.
10. ACCURACY OF INFORMATION
Keeping information accurate and up to date is important to us. An individual may see and correct their Personal Information that we collect. Contact us at the address provided above if you wish to verify your personal information.
YOUR CALIFORNIA PRIVACY RIGHTS
Introduction
Valtir, LLC (“Valtir” or “we”) collects information from you that identifies, describes, or is reasonably capable of being associated with you or your household (“Personal Information”). Personal Information does not include publicly available information in government records or any data that has been deidentified, aggregated, or otherwise anonymized.
Business-to-Business Personal Information
The majority of information Valtir collects, processes, or discloses is business-to-business Personal Information. This means that we collect Personal Information from employees, owners, directors, officers, and contractors of another company when doing business. To the extent you are an individual providing Valtir Personal Information in a business-to-business transaction, you do not have rights to notice or to make requests under CCPA at this time. Valtir will update its notice related to such rights as soon as they become available.
Information We Collect
The Personal Information we collect other than business-to-business Personal Information includes personal identifiers and internet or network activity. We collect this information directly from visitors of our website and use it to analyze site traffic, optimize site performance, and improve our services. We may share this information with third parties, including service providers who help us give you a better user experience. For a full description of this information, as well as how we use and share it, please see our Privacy Policy.
To the extent we collect your Personal Information outside of a business-to-business transaction, you may have the following additional rights over your Personal Information.
Requesting More Information
You may have the right to request information about how we have treated your Personal Information in the past 12 months including:
- The categories of Personal Information we collected;
- The categories of sources from which we collected that information;
- Our business or commercial purpose for collecting that information;
- The categories of third parties with whom we shared that information; and
- The specific pieces of Personal Information we collected about you.
Requesting Access
You may also have the right to receive a copy of the Personal Information collected about you in the past 12 months.
Requesting Deletion
You may have the right to request that we delete the Personal Information we have collected about you. Not all requests to delete can be fulfilled. If we are unable to comply with your request, we will provide a response explaining why your data cannot be deleted.
Exercising Your Rights
If you want to exercise any of these rights, please contact us at:
Valtir, LLC
Attn: Legal Department
15601 Dallas Parkway, Suite 1100525
Addison, TX 75001.
Or by email: media@valtir.com
For all requests submitted via email, please clearly state that the request is related to “Your California Privacy Rights” and provide your name, mailing address, and phone number where you may be reached.
Verification
Before we can respond to your request, we must first verify your identity using your Personal Information. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
Designating an Authorized Agent
You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, you must provide us with written permission to allow your Authorized Agent to act on your behalf.
Third-party Marketing and Selling
We do not currently sell or intend to sell your Personal Information to third parties without first providing you notice and an opportunity to opt-out. We also do not provide your information to third parties for their direct marketing purposes.
Do Not Track
We may collect information about your usage and activity through cookies. Some web browsers or smartphones have the ability to set “Do Not Track” requests to block user activity from being tracked across web pages or devices. Our site does not recognize “Do Not Track” browser signals.
We Will Not Discriminate Against You
We will not unlawfully discriminate against you for exercising any of these rights.
Changes to This Notice
We will continue to review and revise our privacy practices and policies as our technology, services, and use of data evolves. We will not retroactively use or share data in a manner that is materially different from this policy without first providing you notice. This Notice is reviewed and updated annually and we will use reasonable means to inform you of any changes.
How to Contact Us
If you have questions or concerns regarding your information or your rights, please contact us at:
Valtir, LLC
Attn: Legal Department
15601 Dallas Parkway, Suite 1100525
Addison, TX 75001
or email us at media@valtir.com
Date last updated:June 15, 2022
