Last revised and updated:
Steelcase Inc. ("Company", "we" or “us”), respects your privacy and we are committed to protecting it through our compliance with this policy.
This policy describes the types of personal information we may collect from you or that you may provide when you visit marketplace.steelcase.com ("Marketplace") and our practices for collecting, using, maintaining, protecting and disclosing that information. The purpose of Marketplace is to provide a hosted interior design project management and procurement platform that enables users to manage their design projects, review catalogs, and place orders with select vendors for goods and services.
This policy applies solely to information we collect on Marketplace and in e-mail, text and other electronic messages between you and Marketplace. It does not apply to information collected by us offline or through any other means, including on any other websites operated by us or any third party (including our affiliates) that may link to or be accessible from or on Marketplace.
Information We Collect About You and How We Collect It
We may collect several types of information from and about users of Marketplace, including information: (a) by which you may be personally identified and that you will provide on a voluntary basis, such as name and contact data (name, email, company address, phone number) that can be used to identify or contact you online or offline should you wish so to provide you information on our products and services; (b) that is about you but individually does not identify you, such as the contents of your postings on Marketplace; and/or (c) about your internet connection, the equipment you use to access Marketplace, and usage details to improve your access and visit to Marketplace.
We collect this information depending on the context of your interactions with Marketplace, the features you use, and the choices you make. These can include: (a) directly from you when you provide it to us; and/or (b) automatically as you navigate through the site, including usage details, IP addresses and information collected through cookies. We rely on a variety of legal reasons and permissions (each a “legal basis”) to collect and process personal information about you, including with your consent, a balancing of legitimate interests, necessity to enter into and perform contracts with you, and compliance with legal obligations.
Information You Provide to Us
The information you provide directly to us on or through Marketplace may include: (a) information provided at the time of registering to use Marketplace or when requesting further services; (b) records and copies of your correspondence (including e-mail addresses), if you contact us; (c) your responses to surveys that we might ask you to complete for research purposes; (d) your search queries on Marketplace; and/or (e) details of transactions you carry out through Marketplace and their fulfillment.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with Marketplace, we may use automatic data collection technologies to collect information about your equipment, browsing actions and patterns, including: (a) details of your visits to Marketplace and other communication data and the resources that you access and use on Marketplace; and (b) information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is often statistical or aggregate data and does not include direct personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve Marketplace and to deliver a better and more personalized service, including by enabling us to store information about your preferences, allowing us to customize Marketplace according to your individual interests and recognize you when you return to Marketplace.
The technologies we use for this automatic data collection may include:
To comply with applicable laws, we need to ask for your consent to set the performance cookies described above. When you arrive on Marketplace a pop-up message will appear asking for your consent to place cookies on your device. Once your consent has been provided, this message will not appear again when you revisit. If you, or another user of your computer, wish to withdraw your consent at any time, you can do so by altering your browser settings or consulting the menu available in the cookies banner.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, for the following purposes: (a) to present Marketplace and its contents to you; (b) to provide you with information, products or services that you request from us; (c) to analyze and improve our products and services; and (d) to market our products and services. When we process any personal information about you it will be proportional and limited specifically to serving one or more of the purposes described above.
Our Retention of Your Information
We retain personal information only as permitted under applicable laws, including only for as long as necessary to provide the products or services and fulfill the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.
Disclosure of Your Information
We may disclose aggregated information about Marketplace users, and information that does not identify any individual, without restriction under the conditions set forth in this section.
Accessing and Correcting Your Information
Marketplace users can access and control their personal information. You can review and change your personal information by logging into Marketplace and visiting your account profile page. You may also send us an e-mail using the Contact Us" form or to firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We cannot delete all your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Where We Store and Process Your Information
Given the global nature of our business and the centralization of certain business activities, personal information may be stored and processed internally at different group levels (e.g., global, regional, and local) for lawful purposes where Company or its affiliates, subsidiaries or service providers (including Marketplace’s cloud services provider) operate facilities. We recognize that the EU/EEA countries have an omnibus data protection regime that generally restricts the transfer of personal information about individuals in the EU to the United States and certain other countries, unless there is “adequate protection” for such information when it is received. This is set out in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to processing of personal data and the free movement of that data (“GDPR”). To address GDPR and equal restrictions in other countries or regions, we apply a consistent set of rules to all transfers of personal information amongst Company entities regardless of their location whether within or outside of the EU/EEA countries. To provide adequate protection for transfers of personal information, Company along with its affiliates, subsidiaries or service providers enter into the Standard Contractual Clauses for the Transfer of Personal Data to Third Countries (“Model Contract”) pursuant to European Commission Decision 2004/915/EC of 27 December 2004. Because Marketplace is intended to potentially connect users worldwide, if you do not wish to have information that we collect about you or that you provide to us, including any personal information, transferred to all countries where other internal and external users are located, then you should not use Marketplace.
We have implemented and will maintain appropriate technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on secure servers behind firewalls, and we will pursue continuous efforts and technical monitoring to anticipate attacks, theft, and data deterioration. In case a security breach should occur, we will undertake to comply with applicable data protection laws, including applicable security breach notification laws.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to Marketplace, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to Marketplace. Any transmission of personal information to us is at your own risk. We are also not responsible for circumvention of any privacy settings or security measures contained on Marketplace.
Unless otherwise stated, Steelcase Inc. and, for those in the European Economic Area and Switzerland, Steelcase S.A. are the data controllers for personal information we collect through the Marketplace and other means subject to this policy. Our addresses are:
Steelcase Inc., Attn: Global Privacy Lead, 901 44th Street SE, Grand Rapids, Michigan 49508 USA. Telephone toll-free: 800-333-9939.
Steelcase S.A., Attn: Data Protection Officer, Espace Europeen de l’Enterprise, Schiltigheim 67300 France.