This privacy notice (“Privacy Notice”) applies to any visitor of our website (hereinafter referred to as “Visitors”), as well as to Sonora Port customers and business partners (collectively referred to as “You”) as specified below.
Sonora Port is aware and concerned of the issue of confidentiality in online and offline dealings and is committed to transparency regarding the protection of individual privacy. This Privacy Notice is intended to inform You about the general approach Sonora Port may use in collecting, using and disseminating personal information via the Site and offline through our interactions with You via business dealings, and other activities.
The Site is operated on behalf of Sonora Port located in the USA. At Sonora Port, it is our policy to create Site content that demonstrates our respect for Visitors’ privacy and allows us to understand our Visitors. We may request personal information from You as a Visitor, including Your name, home address, email address or telephone number, when You interact with the Site, such as to respond to Your requests or to enable You to register to use certain features of this Site or to be provided with certain services offered via the Site. Sonora Port may process such personal information in order to provide the Site and its services (including marketing services) to You, to monitor compliance with this Privacy Notice, any other terms and conditions applicable to Your usage of the Site and with applicable laws, for security purposes and to set up access permissions to certain other pages on the Site.
An internet protocol address, or IP address, is automatically assigned to Your computer when You access the internet, and is used by web servers to identify Your computer. When You access our Site as a Visitor, we may log Your computer’s IP address. We log the IP address for system administration purposes, for auditing the use of the Site, and for collecting statistical information for marketing and other purposes. Additionally, we may use Your IP address to identify a particular Visitor if we believe it is needed to enforce compliance with the terms of this Privacy Notice, any other terms and conditions applicable to Your usage of the Site and with applicable laws or to protect our company, employees, Site, or customers.
We may use tracking scripts or “tracers” that recognize a unique identifier from a cookie placed on Your computer by another non-Sonora Port website. These are used by Sonora Port to gauge the success of our own advertising. For instance, we may use a tracer to determine whether You visit our recruiting pages after visiting a career site where Sonora Port placed a banner advertisement. We do not use tracers to gather information on Your use of the internet unrelated to Sonora Port, or to determine Your personal information.
Sonora Port may use an advertising server developed by a third party to display ads on the Site. Some of these ads may contain cookies that are set by third parties (advertisers, sponsors). We do not have access to these cookies or any information that they contain. This Privacy Notice does not cover any use of information that a third-party ad server may have collected from You.
Web beacons are small files that we may place on our Site, which count the number of unique Visitors that have visited a specific page on the Site and the number of times a given page has been displayed. This information is collected generally in the aggregate and is not linked to any personal information (except as described below).
We may use “pixel tags,” or short pieces of code, to better measure the effectiveness of our content. These also allow social networks and other services to deliver content to You based on Your visit to our website.
We may track Your visit by providing You with a unique universal resource locator, or URL, via an e-mail, a letter or other communication. When You use this unique URL, our website registers Your visit. We use this information to measure the effectiveness of our advertising and other content with You.
Our information collection practices operate as described in this Privacy Notice independent of any “do-not-track” choice You make.
If You are a representative or other personnel member of a Sonora Port customer, or an individual customer, the Sonora Port entity with whom You are interacting may collect and process as a data controller and data owner the following categories of personal information about You through our engagements with You: Your name; personal/work contact information; photograph (where permitted by applicable law); employee, contractor, or government identification; country of origin; nationality; content of communications in our exchanges regarding customer service; computer usage information related to a customer’s use of its own company equipment, systems, and other resources, Internet Protocol (IP) address or other device location information of a desktop, laptop or other devices used by or on behalf of a customer to access the customer’s computer or telecommunications network of Sonora Port onsite or through a remote connection; and other personal information incidentally accessed on customer’s equipment or systems in connection with its managed security and professional services. We process customer personal information for the following purposes: general business administration; managed security and professional services; speech recognition and call center analytics; customer support; direct marketing (e.g., email, text message, postal mail, behavioral advertising); fulfilment of requests; tracking payment of order; customer relationship management; responding to inquiries; and exercising a right or obligation imposed by law or contract (e.g., mandatory reporting obligations). Please contact Sonora Port Company below in order to obtain further details on the Sonora Port entity that is Your data controller / data owner in this context.
If You are a representative or other personnel member of a Sonora Port business partner, or individual business partner, the Sonora Port entity with whom You are interacting may collect and process as a data controller and data owner the following categories of personal information about You: Your name; address; professional contacts or organizations; date of birth; photograph (where permitted by applicable law); applicable ID number (passport or national ID); qualifications; work history; job title; educational history; prohibited party or other criminal background information. We may process such business partner personal information for the following purposes: general business administration; account management; IT helpdesk and support services; direct marketing (e.g., email, text message, postal mail); exercising a right or obligation imposed by law or contract (e.g., mandatory reporting obligations); and vendor management.
Sonora Port may use Your personal information only as set forth herein (especially in Section 1).Data collected via the Site using cookies, tracers, web beacons, pixel tags and similar technologies may be analyzed in the aggregate to determine collective characteristics of Visitors, to understand traffic patterns, sales information and behavior of Visitors on the Site. Such information also may be shared in the aggregate with third parties for advertising purposes, to enhance the Site, to enhance our products and services, and to analyze how and where best to use our resources.
Although Sonora Port is under no obligation to monitor the Site, we may monitor, store, review and share with third parties any information, including Your personal information, obtained on or through the Site, including if it is needed or requested to satisfy any applicable governmental law, regulation, investigation or proceeding.
Sonora Port may transfer, disclose or share Your personal information with its affiliates as necessary for the purposes stated therein.
Generally, Your personal information will not be shared with third parties not affiliated with Sonora Port. From time to time we may transfer, disclose or share Your personal information with third parties that Sonora Port has engaged specifically to handle and deliver certain online activities or other support services, including, but not limited to, conducting contests and sweepstakes, hosting or marketing services. Such third parties will receive Your personal information needed to perform these functions, but we do not allow them to use it for other purposes without Your consent. When You provide Your personal information to Sonora Port in response to a contest, sweepstake, or other project consistent with our Terms and Conditions, You may thereby consent that we publicly disclose and use Your personal information, as permitted by applicable law.
Sonora Port may transfer business partner personal information for the purposes described in Section 1 moreover to the following types of third parties: ethics investigations providers, financial transaction messaging providers, legal advisors, document management systems providers, screening and escalation services providers, and network and IT support providers. Sonora Port transfers customer personal information for the purposes described in Section 1 moreover to the following types of third parties: financial transaction messaging providers, and legal advisors.
Sonora Port may also disclose Your personal information to courts, governmental and law enforcement authorities, legal counsel and similar third parties (1) where such disclosure is required or permitted by law; (2) to protect Sonora Port’s legal rights to the extent authorized or permitted by law; or (3) in an emergency where the health or safety of You or another individual may be endangered.
Sonora Port may transfer personal information in connection with the sale or acquisition of one or more of our businesses or subsidiaries to a different company that agrees to offer equivalent safeguards for the use and disclosure of such information.
We maintain administrative, technical and physical safeguards designed to protect the personal information You provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. While Sonora Port makes extensive effort to prevent unauthorized access to personal information, the security of information transmitted via the internet cannot be guaranteed. Any information disclosed online can potentially be collected and used by others aside from the intended recipient. Thus, Sonora Port cannot warrant that Your personal information will not be disclosed to or accessed by unauthorized parties.
6.1 We offer You certain choices in connection with the personal information we collect from You.
To update Your preferences, ask us to remove Your personal information from our mailing lists, exercise Your data privacy rights or submit a request, please contact us as indicated below in Section 12.
6.2 To the extent provided by law, You may request access to the personal information we maintain about You or request that we correct, amend, delete, restrict or block the personal information. Where provided by law, You may withdraw at any time with effect for the future any consent You previously provided to us or object at any time on legitimate grounds to the processing of Your personal information, and we will apply Your preferences going forward.
6.3 In compliance with applicable law, we may reject Your request if we need to retain Your personal information, to enforce the terms of this Privacy Notice, resolve disputes, or provide information to satisfy applicable investigations or proceedings. Additionally, Your personal information may be retained in back-up files created by our network’s back-up systems. However, we will not keep Your personal information longer than is necessary to achieve these purposes.
6.4 To exercise Your privacy choices for marketing emails, please click the opt-out link on the email You received or contact us via email at contact@SonoraPort.com. Please indicate if You would prefer that we use a different email address or communication method. Restricting our contact methods may make it more difficult for us to keep You informed about new products and services that can benefit You. These choices do not apply to transactional or relationship emails or the display of online advertising. You can revoke Your choice at any time by contacting us using one of the methods provided.
7.1 The Site may provide links to other independently owned, controlled, and/or managed Site whose content we believe will be of possible interest and value to our Visitors. In many cases, these links represent cooperative projects or mutual links established with the organizations connected with these Site. We don’t control the content of the third party Site accessed by You via these links on our Site. These third party Site may send You their own cookies, collect data, or solicit personal information. Once You leave our Site (You can generally tell on which Site You are by checking the URL in the location bar on Your browser), the provision and use of any information You provide is governed by the privacy statement of the operator of the website You are visiting. That privacy statement may differ from ours. If You can’t find the privacy statement of any of these Site via a link from that website’s home page, You should contact that third party website operator directly for more information.
7.2 To the extent that the Site includes third-party advertisements, the privacy statement of the advertiser providing the advertisement will govern the use of Your personal information collected during Your access to the advertisement. While we identify sponsor and advertiser areas of our Site, we do not control these cookies or the content of these third parties. Sonora Port does not control linking practices of advertisers or sponsors and does not monitor or claim responsibility for any content or privacy practices of such Site. Once You have left our Site, You must read the privacy statement of the advertiser or sponsor to see how Your personal information will be handled.
7.3 Sonora Port may use the Site as an entry into other networked web pages and Site operated by Sonora Port (together, the “Transaction Site”). Please note that an individual Transaction Site may adopt privacy terms particular to the purpose of such Transaction Site or the transaction(s) taking place on such Transaction Site. As Transaction Site are generally affiliated with commercial transactions that You or Your business may have with Sonora Port or Sonora Port affiliates, particularly those which are password-protected or subject to subscriptions, the privacy terms governing such Transaction Site may be supplemented or superseded by specific privacy statements and/or agreements.
7.4 We specifically recommend that children check with their parents before connecting to any new Site.
Country, State and Regional Specific Data Privacy Information
We have implemented additional privacy safeguards and do not collect personally identifiable information from children under the age of 13.
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. Sonora Port does not distribute Your personal information to outside parties for their direct marketing, or any other purpose, except as provided for in this Privacy Notice, without Your consent. See also Section 4, Use of Information.
If You are located in the European Union (“EU”) / European Economic Area (“EEA”) or otherwise protected by European data protection law, the following applies.
To provide an adequate level of protection for personal information received from the EU/EEA, Sonora Port participates in the EU-U.S. Privacy Shield Framework (“Privacy Shield” or the “Framework”). Sonora Port adheres to the Privacy Shield Principles as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the EU and the United Kingdom to the United States, which includes personal information about Sonora Port EU employees, job applicants and individual contacts of business partners and customers. We provide notice to EU employees through separate internal company policies, and to job applicants through our recruiting and job posting Site. We are committed to subjecting such personal information to the Privacy Shield, including its Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.
We may transfer the personal information we collect to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which the information was initially provided.
If there is any conflict between the terms in this Section on Privacy Shield and the Privacy Shield Principles, the Privacy Shield Principles shall govern to the extent of the conflict. To learn more about the Privacy Shield program visit www.privacyshield.gov, and to located and view our certification, please visit https://www.privacyshield.gov/list.
In addition to the rights provided under local law, You are afforded under Privacy Shield a specific right to access Your personal information. You may also have the right to exercise choices (opt-out) from our use of Your personal information for direct marketing purposes. To exercise this right, please follow the instructions in any direct marketing message You may have received. We do not otherwise use or disclose Your personal information in a manner that is subject to choice requirements under the Framework.
Please contact us as specified below in Section 12 if You have any questions, need access to Your personal information, or otherwise need assistance. We remain responsible for our collection, use and disclosure of Your personal information in accordance with the Framework. We also are responsible for third party agents that are processing such personal information on our behalf, unless we prove that we are not responsible for the event giving rise to the damage. In certain situations, we may be required to disclose Your personal information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
If You have an unresolved concern about Your personal information that we have not addressed satisfactorily, we have committed to cooperate with the panel established by the EU Data Protection Authorities to serve as our independent dispute resolution body for the Framework. We are also subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Framework. In addition, under certain conditions, more fully described on the Privacy Shield website, individuals may invoke binding arbitration for non-monetary issues when other dispute resolution procedures have been exhausted.
Please contact us using the contact information under in Section 12 below if You have any questions related to the Framework, wish to exercise Your rights of access, or wish to seek other assistance as described above.
10.2 Additional Information under the EU General Data Protection Regulation
This Section provides additional information as required by the EU General Data Protection Regulation (“GDPR”).
10.2.1 Data Controller and Legal grounds for the processing
If You are a Visitor of the Site, Sonora Port as identified in Section 12 is the data controller of Your personal data. If You are a business partner or customer, the Sonora Port entity with whom You interact is the data controller. Please contact Sonora Port in order to receive the contact details of such other Sonora Port entity acting as Your data controller.
Sonora Port relies on the following legal grounds for the processing of Your personal information as provided under the GDPR:
The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of You which require protection of personal data, in particular if You are a child; such legitimate interests are the provision of the Site and its services as requested by You, the promotion and advertisement of our services, communicating with you, and compliance with legal obligations and internal policies and procedures (Art. 6 (1) lit. f GDPR)
Your consent to the processing of Your personal information for one or more specific purposes;
The processing is necessary for the performance of a contract to which You are a party or to take steps at Your request prior to entering into a contract; the processing is necessary for compliance with a legal obligation to which we are subject; The provision of Your personal information is typically not required by law or contract and is therefore voluntary. However, if You do not provide Your personal information, Sonora Port may not be able to make the Site and its services available to You and to response to Your request or inquiry. Similarly, if You have entered or want to enter into a contract with Sonora Port, Your personal information may be necessary to pursue this purpose.
Sonora Port is located in the US and You therefore need to expect that Sonora Port and other recipients of Your personal information are located outside the EU/EEA. Sonora Port and its US affiliates are certified under the EU-U.S. Privacy Shield and thereby recognized as providing an adequate level of data protection from a European data protection law perspective.
Other recipients located outside of the EU/EEA are also certified under the EU-U.S. Privacy Shield or are located in countries with adequacy decisions pursuant to Art. 45 GDPR (in particular, Canada (for non-public organizations subject to the Canadian Personal Information Protection and Electronic Documents Act), Switzerland, Israel), and, in each case, the transfer is thereby recognized as providing an adequate level of data protection from an European data protection law perspective.
Other recipients might be located in countries which do not adduce an adequate level of protection from an European data protection law perspective (in particular, certain recipients in the USA which are not certified under the EU-U.S. Privacy Shield). We will take all necessary measures to ensure that transfers out of the EU/EEA are adequately protected as required by applicable data protection law.
With respect to transfers to countries not providing an adequate level of data protection, we will base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority (Art. 46(2)(c) or (d) GDPR), approved codes of conduct together with binding and enforceable commitments of the recipient (Art. 46 (2)(e) GDPR), or approved certification mechanisms together with binding and enforceable commitments of the recipient (Art. 46 (2)(f) GDPR). You can ask for a copy of such appropriate safeguards by contacting us as set out in Section 12 below.
The data transfers to Sonora Port affiliates and other third-party service providers which are neither certified under the EU-U.S. Privacy Shield nor in a country with other adequacy decision are typically protected by standard data protection clauses adopted by the European Commission (Art. 46(2)(c) or (d) GDPR).
Your personal information is stored strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the personal information is collected, in accordance with applicable data protection laws. When Sonora Port no longer needs to use Your personal information, we will remove it from our systems and records and/or take steps to properly anonymize it so that You can no longer be identified from it (unless we need to keep Your personal information to comply with legal or regulatory obligations to which Sonora Port is subject).
Personal information will in principle be deleted 3 years after the last interaction and business contact between You and Sonora Port, unless a longer retention is necessary to protect our interests. However, we will retain Your contact details and interests in our products or services for a longer period of time if Sonora Port is allowed to continue sending You marketing materials.
In addition to or supplementing the rights set out above in Section 5 and 9, You have the following rights under GDPR: (i) request access to Your personal information; (ii) request rectification of Your personal information; (iii) request erasure of Your personal information; (iv) request restriction of processing of Your personal information; (v) request data portability; (vi) object to the processing of Your personal information (including objection to profiling), and (vi) withdrawal of Your consent at any time. Below please find further information on Your rights to the extent that the GDPR applies. Please note that these rights might be limited under the applicable local data protection law.
Right to request access to Your personal information: As provided by applicable data protection law, You have the right to obtain from us confirmation as to whether or not personal information concerning You is being processed, and, where that is the case, to request access to the personal information. This access information includes – inter alia – the purposes of the processing, the categories of personal information concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict Your right of access. You may have the right to obtain a copy of the personal information undergoing processing free of charge. For further copies requested by You, we may charge a reasonable fee based on administrative costs.
Right to request rectification: As provided by applicable data protection law, You have the right to obtain from us the rectification of inaccurate personal information concerning You. Depending on the purposes of the processing, You may have the right to have incomplete personal information completed, including by means of providing a supplementary statement.
Right to request erasure (right to be forgotten): As provided by applicable data protection law, You have the right to obtain from us the erasure of personal information concerning You and we may be obliged to erase such personal information.
Right to request restriction of processing: As provided by applicable data protection law, You have the right to obtain from us that we restrict the processing of Your personal information. In such case, the respective information will be marked and may only be processed by us for certain purposes.
Right to request data portability: As provided by applicable data protection law, You have the right to receive the personal information concerning You, which You have provided to us, in a structured, commonly used and machine-readable format and You may have the right to transmit those information to another entity without hindrance from us.
Right to object: Under certain circumstances, You have the right to object, on grounds relating to Your particular situation, at any time to the processing of Your personal information by us and we are required to no longer process Your personal information. Such right to object especially applies if we collect and process Your personal information for profiling purposes in order to better understand Your interests in our products and services or for certain types of direct marketing.
If You have a right to object and if You exercise this right, Your personal information will no longer be processed for such purposes by us.
Such a right to object may, in particular, not exist if the processing of Your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Right to withdraw Your consent: If You have declared Your consent regarding certain collecting, processing and use of Your personal information (in particular regarding the receipt of direct marketing communication via email, SMS/MMS, fax, and telephone), You can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
To exercise Your rights, please contact us as stated under Section 12 below. You also have the right to lodge a complaint with the competent data protection supervisory authority in the relevant Member State (e.g., the place where You reside, work, or of an alleged infringement of the GDPR).
Changes to this Privacy Notice, will be posted on this page, with a new effective date at the top. If we make material changes to our Privacy Notice that could affect the personal information You previously submitted to us, we will provide You notice and an appropriate opportunity to consent as required by law.
If You have any questions or concerns regarding Sonora Port’s Privacy Notice or its use of personal information or if You want to exercise Your rights as described in this Privacy Notice or as otherwise granted under applicable law, please contact us at contact@SonoraPort.com