GDPR Website Privacy Statement

Effective Date:  May 25, 2018

What is the scope of this Privacy Statement?

This Privacy Statement applies to ePlus websites, mobile applications, and digital services that link to or post this Privacy Statement.  This Privacy Statement is intended to let you know what Personal Data (as defined below) ePlus inc., including our affiliated entities (referred to collectively as “ePlus,” “we,” “our,” or “us”) collect about you, how we collect your Personal Data, for what purposes we use your Personal Data, to whom we disclose your Personal Data, and what rights you have to limit our use of your Personal Data.  In this Privacy Statement, we will collectively refer to the websites, applications, and digital services that link to or post this Privacy Statement as “websites.”

What Personal Data do we collect about you?

Through our websites linking to this Privacy Statement and by information you provide directly to ePlus, we collect and process Personal Data, including data that does not directly identify you by name or include your contact information, but which may be used to identify that a specific computer or device has accessed our website and which if combined with certain other information could be used to identify you.

 

The Personal Data we process about you includes the following categories of Personal Data:

 

  • Name;
  • Login Information;
  • Business contact information (address, telephone, email address);
  • Demographic data (date of birth, gender, country of residence);
  • Online identifiers
  • Internet Protocol (IP) address;


  • Third party cookies;
  • Website Interactions (Uniform Resource Locators (URL) Clickstream, Scrolling, Clicks, Mouse-overs)
  • Social media use and utilization;
  • Geo-location data, as may be transmitted from your smart phone or other location-aware devices

 

We collect Personal Data on your visit to our websites through cookies, IP information, or other data provided by your web browser or device.  We also collect data that you voluntarily provide to us through your interactions with our websites, contacting us through email forms or if you call, email, write to us or contact us through social media. 

 

We combine all of this data, together with data provided by third parties as set forth below, to offer you services and to otherwise facilitate the activities described in the following section.

 

How will we use your Personal Data?

Processing of your Personal Data includes where we may record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, dissemination, or otherwise make available, align or combine, restrict, erase, or destroy your Personal Data.

We process your Personal Data for the following purposes:

  • Responding to your requests for information, products, or services;
  • Administering or carrying out obligations of an account you have established with us;
  • To communicate product information to you;
  • To communicate with you about any comments, queries or feedback you might have about us or the website;
  • To communication changes about or make improvements to our website;
  • Authorizing, granting, administering, monitoring, and terminating access to or use of ePlus systems, facilities, records, property, and infrastructure;
  • Tracking your interactions (online and offline) with us;
  • Managing data subject requests;


  • Our company compliance, facility and network security purposes;
  • Auditing our programs and services for compliance purposes;
  • Internal investigations of possible misconduct or failure to comply with our policies and procedures;
  • Legal proceedings and government investigations (such as pursuant to warrants, subpoenas, and court legal orders);
  • Where we have Legal obligations to process the personal data;
  • Statistical analysis, including Google Analytics
  • Website administration; and/or
  • Marketing Activities, including Third Party Cookie Tracking and Creating an Interest-based Profile related to your interactions with us or others
 
 

 

For any additional purposes where we are required to notify you and get your consent, including those purposes required by local law, we will obtain your consent before we process your Personal Data for those purposes. 

What is our legal basis for Processing your Personal Data?

The applicable legal basis for which we process your Personal Data for the specific purposes listed above, include the following:

  • Based on your consent:  In some cases, at the point at which you provide Personal Data, we will ask you for your consent to collect and process your Personal Data.  If you choose to provide us with your consent, you may later withdraw your consent (or opt-out) by contacting us as described in the “how do you contact us” section below.  Please note that if you withdraw your consent it will not affect any processing of your Personal Data that has already occurred.  Where we process your Personal Data based on consent, we will provide more detailed information to you at the time when we obtain your consent.

 

  • Compliance with applicable laws or performance of a contract:  In specific circumstances, we may need to process your Personal Data to comply with a relevant law/regulation or to fulfill our obligations under a contract to which you are subject.  Where we process your Personal Data to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information unless it would impede our legal obligations.  Where we are processing to fulfill our contract obligations under a contract where you are a party, you might not be able to object to this processing, or if you do choose to opt-out or object to our processing, it may impact our ability to perform a contractual obligation that you are owed.

 

  • Our legitimate interest:  We process your Personal Data based on our legitimate interests in communicating with you and managing our interactions with you regarding our products and services.  In addition to the other rights you may have described below, you have the right to object to such processing of your Personal Data.   You can register your objection by contacting us as described in the “how do you contact us” section below.

Cookie and similar technologies that collect Personal Data

Cookies

This website uses a technology called a "cookie". A cookie is a small data file that a website can place on your computer’s hard drive, where your internet browser files are kept. A cookie saves you the trouble of reentering certain information in some registration areas because cookies can be used to enable a site to “remember” information a visitor has previously inputted. A cookie also helps deliver content user-specific information to you and track how sections of the website are used. Cookies can be placed on your computer both by us and by third parties with whom we have a contractual relationship, such as web analytic services and advertising network services. With most Internet browsers or other software, you can change your browser settings to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please check your browser instructions to learn more about these functions. If you reject cookies, functionality of the site may be limited, and you may not be able to take advantage of many of the site's features. Click here to see our website cookie policy. 

 

Web beacons

Our websites and emails use a technology known as web beacons (also known as an “action tag” or “clear GIF technology”) that allows the collection of web log information. A web beacon is a tiny graphic on a web page or in an e-mail message designed to track pages viewed or messages opened. Web log information is gathered when you visit one of our websites by the computer that hosts our website (called a "webserver").

Web beacons also help analyze the effectiveness of websites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site.

 

Do Not Track

There are different ways you can prevent tracking of your online activity. One of them is setting a preference in your browser that alerts websites you visit that you do not want them to collect certain information about you. This is referred to as a Do-Not-Track (“DNT”) signal. Please note that currently our websites and web-based resources do not respond to these signals from web browsers. At this time, there is no universally accepted standard for what a company should do when a DNT signal is detected.

 

Google Analytics

Google Analytics is used to help make our website work better and to help us understand what parts of the website are being utilized. Google Analytics uses technical tools, such as first-party cookies and JavaScript code, to collect information about visitors. Google Analytics service tracks visitors to the site who have JavaScript enabled. Google Analytics anonymously tracks how visitors interact with a website, including where they came from and what they did on a site. Google Analytics collects the information set forth above from users.

 

This information is used to administer and update the website, and we will also assess whether the visitors to the site match the expected site demographics and determine how key audiences are navigating the content.

 

First-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) will be used to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to this site.

 

A. Opt-Out Provision:

Google analytics offers an opt-out provision for website visitors who do not want their data to be collected. You can receive more information about this option here: http://tools.google.com/dlpage/gaoptout.


B. Google's Use of Data:

Google and its wholly owned subsidiaries may retain and use, subject to the terms of its Privacy Policy (located at http://www.google.com/privacy.html, or such other URL as Google may provide from time to time), information collected in your use of the Google Analytics Information Disclosures and Sharing.

 

Social Media Plugins

Our websites use Social Media Plugins to enable you to easily share information with others. When you visit our websites, the operator of the social media plugin that is on our website can place a cookie on your computer that lets that operator recognize individuals on their website who have previously visited our sites. If you have previously logged into the social media website while browsing on our website, social media plugins allows that social media website to receive directly identifiable information about you that shows you have visited our website. The social media plugin collects this information for visitors who have logged into social networks, whether or not they specifically interact with the plugin on our website. Social media plugins also allow the social media website to share information about your activities on our website with other users of their social media website. ePlus does not control any of the content from social media plugins. For more information about social plugins from social media websites you should refer to those sites’ privacy and data sharing statements.

 

Children’s Personal Data

This site is not intended for or designed for individuals under the age of 16. We do not knowingly collect Personal Data from any person under the age of 16. 

 

How do we protect your Personal Data?

We maintain numerous security standards and procedures to help prevent unauthorized access to confidential information about you. Our site uses a combination of encryption technology and authentication to protect your Personally Identifiable Information. As long as the web browser you are using supports Secure Sockets Layer (SSL), your information will be submitted to us with a high level of security. We update and test our security technology on an ongoing basis. We have procedures limiting employee access to Personally Identifiable Information to those employees who have a business reason to know such information about you. We will only transfer your Personal Data to third parties acting on our behalf where we have received written assurances that your Personal Data will be protected in a manner consistent with this Privacy Notice and our privacy policies and procedures.

How long do we retain your Personal Data?

Your Personal Data will be maintained for the duration of your relationship with us.  Please note that certain information could be retained for longer periods of time if we have continuing obligations to you or your employer or if required by local law or other legal or regulatory requirements.

Which third parties provide us with Personal Data?

We receive Personal Data from Google Analytics, as discussed above.  We also receive Personal Data, which we combine with the data collected on this website, from the following sources: LinkedIn, Marketo, ShareThis, SEMrush and HotJar.

What automated decisions are made using your Personal Data?

We or our affiliates use your Personal Data to provide personalized experiences on our sites, as well as to decide which marketing materials are provided to you on and off of our sites.

With whom do we share your Personal Data?

We share your personal data with our service providers who facilitate the purposes described above.  We disclose information to third parties who provide us with various business services, including monitoring and maintaining the website, for example. We also share Personal Data with third parties with whom we are working to provide you with other services or information.

The Personal Data collected on this website is also disclosed by ePlus to third parties acting on its behalf, for processing, communications (such as e-mailing and other mailings) and other purposes consistent with this Privacy Notice.  These recipients include the following:

  • Marketing vendors
  • Website operators

We have legal or contractual obligions to disclose Personal Data collected on this website in the following instances: when we receive legal process requiring disclosure, or in connection with investigations of inappropriate or illegal activities. We may also disclose information we collect to legal counsel, law enforcement, and other appropriate authorities in special cases, including: (i) when we have a reason to believe that such disclosure is necessary to identify, contact, or bring a legal action against someone who may be causing injury to or interference with our rights and property or those of any other person; or (ii) when we believe that it is required by applicable laws, court orders, or government regulations.

Aggregate, non-personally identifiable visitor information is shared with third parties for marketing, advertising, or other lawful uses.

If all or part of ePlus is merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. Your information may also be included among the assets affected by financing agreements undertaken by ePlus.

Will ePlus transfer your information internationally?

Our  website and online resources are owned and operated in the United States, and the information you provide may be accessible by our affiliates and vendors in other countries. If you are visiting this site from a country other than the United States, your information will cross an international boundary. The level of protection for your information in the United States may not be the same as the level of protection in your country. Your use of the website will result in the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.

Links to Third Party Websites

As a convenience to our visitors, this website may contain links to other sites owned and operated by third parties that we believe may offer useful information. The policies and procedures we describe here do not apply to those sites. We are not responsible for the collection or use of Personal Data by or on any third party sites. Therefore, we disclaim any liability for any third party's use of Personal Data obtained through using the third party web site. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.

 

What are your rights?

You have the right to see and get a copy of your Personal Data, including an electronic copy, that we have as well as to ask us to make any corrections to inaccurate or incomplete Personal Data we have about you.  You can also request that we erase your Personal Data when it is no longer needed for the purposes for which you provided it, restrict how we process your Personal Data to certain limited purposes where erasure is not possible, or object to our processing of your Personal Data. In certain circumstances you are able to request that we send a copy of your Personal Data to a third party of your choosing. 

To exercise any of these rights, please contact us as set forth in the “how do you contact us” section below.   You also have the right to lodge a complaint with the supervisory authority (see details under “remedies” below) where you believe that your rights have been violated.

What if we revise this Privacy Statement?

From time to time we may make changes to this Privacy Statement to reflect changes in our legal obligations or the ways in which we process your Personal Data.  Any changes to this Privacy Statement will be posted on this website. 

How do you contact us if you have any questions or concerns?

Please contact the designated ePlus employee below using the information that follows to:

  • Ask questions;
  • File a concern or complaint;
  • Opt-out of a program or service; and/or
  • To exercise any of your rights listed above, including access, correction, portability, objection, restriction, and erasure.

 ePlus’s Designated Privacy Contact
 Mailing Address:
Attention:  General Counsel ePlus
13595 Dulles Technology Drive
Herndon, VA  20171
 Email Address: compliance@eplus.com

 

What remedies do you have available?

For more information about your privacy and data protection rights, or if you are not able to resolve a problem directly with us and wish to make a complaint, please contact your country-specific data protection authority.  You may consult a list of data protection authorities here http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061