Legal Notice

Privacy Policy


Effective Date: 7/5/2018

About Haworth

Haworth, Inc. is a privately-held, family-owned corporation headquartered in Holland, Michigan USA which designs and manufactures adaptable workspaces for businesses.


Overview

At Haworth, Inc., your privacy is important to us. We process personal data in different contexts by fully respecting your privacy and your rights and freedoms as part of our commitment to ethical and responsible practices. Haworth, Inc. or one of its subsidiaries listed at the end of this notice is the controller responsible for the processing of your personal data according to the General Data Protection Regulation (GDPR) if you reside in the European Economic Area.

Your privacy is important to Haworth, Inc. We also understand that privacy is very important to you. This Privacy Policy Notice (“Policy”) explains how Haworth may use and disclose information we collect from and about you when you visit this website or when you otherwise interact with us, as well as your ability to control certain uses of it.

This website is operated by Haworth, Inc. and applies to certain of its subsidiaries (hereafter, “Haworth”). These subsidiaries may also operate other websites. Please review the privacy policy posted on those other websites when you visit them.

Please also read our website Terms of Use (“Terms of Use”) to understand the general rules about your use of this website. Except as written in any other disclaimers, policies, terms of use or other notices on this website, this Policy and the Terms of Use are the complete agreement between you and Haworth with respect to your use of this website.

You may be subject to additional terms or policies. For instance, during the provision of certain services to our customers, when you access particular services or materials on certain areas of this website or by following links that take you away from this website.


Types of personal data we collect and use

Haworth classifies personal data as any information related to an identified or identifiable individual. Depending on your interactions with Haworth, we collect and use different types of personal data from visitors, customers, prospective customers and agents.

We value the privacy of our website visitors. We do not sell your personal data. We will only collect and use your information as explained in this Policy. This section gives a brief overview of our data collection and use. Please contact us at privacy@haworth.com if you have any questions.

Information we collect directly from you

The categories of information that we or our service providers may collect directly from you include the following:

  • Clients, vendors and suppliers: We collect name, contact information for key personnel, and personal data that you provide us on a voluntary basis such as payment and financial order processing information.
  • Prospective clients: We collect name and contact information.
  • Influencers: We collect name, contact information, role and preferences from architecture and design firms, project management firms, or potential agents of customers.
  • Visitors to our locations: We collect name, contact information and video images from security cameras in some of our office buildings.
  • Prospective employees:  We collect name, contact information, resumes and other information for the purposes of recruitment.

Information we collect about your use of the website

The following are examples of the other categories of information which we may collect when you visit and use our websites:

  • Technical information collected from your computer or mobile device (e.g. your IP address, browser type, operating system);
  • Information about your usage of our websites (e.g. the pages you visit when using the website, the search terms you enter on the website, how often you use the website, and the pages you access before and after accessing the website).

For more information about these activities, please see our cookies policy.

Information we collect from other sources

The following are examples of the categories of information we may collect from other sources (e.g. events, sales calls, etc.).

  • Personal and contact details (e.g. name, phone number, email address, mailing address) from our subsidiaries and affiliates in order to more efficiently manage our customer relationships and to improve the quality of our customer experience;
  • Details about your advertising preferences (e.g. products purchased, interaction with advertisements online);
  • Information from email campaigns and customer nurturing programs (e.g. email address, role, content preferences); and
  • Information from lead generation (e.g. email address, role, browsing behavior and content preferences).

Uses and purposes of Personal Data

The purposes for which we collect and use your personal data may vary depending on the type of relationship you have with us, such as if you are one of our customers or a website user. Haworth collects and uses personal data according to the purpose limitation principle.

The information we collect is used to:

  • Administer your account. If you have a commercial relationship with Haworth, we use your personal data to develop our customer relationship and to comply with legal, regulatory, insurance, security and processing requirements.
  • Maintain our business records for commercial relationships using customer information to ensure the proper operation of the day-to-day business, such as by personalizing your site experience, allowing customer service to better respond to your requests, quickly processing any transactions and administering sales activities.
  • Respond to prospective customer requests for information, products or services, and for marketing activities such as administering a contest, promotion, survey, or other site feature.
  • Send marketing messages. When required by applicable law, we obtain your consent prior to sending any direct marketing communications. You may change your preferences or opt out of all e-mails at any time by clicking on the "unsubscribe" link found in each e-mail.
  • Improve our products, including by conducting analytics of user perceptions of furniture and space designs, collecting statistics about space utilization, to generating profiles for of types of space layouts used by customers to the extent that it is in our legitimate interest to do so.
  • Operate this website, including by managing your account or subscriptions, storing your preferences and settings, providing interest-based advertising to website visitors, generating aggregated statistics and analyzing how you use our website and online services. For additional information on these activities, see our cookies policy.
  • Comply with our legal obligations, including by complying with tax reporting obligations and responding to legitimate law enforcement requests.

We will seek your consent before using your personal data for any purposes not listed above.

Your contact information

When you provide us with your contact information, we will use that information to provide services related to this website. For example, if you purchase a product on our site, we will use your mailing address to ship your order. We may also send you e-mail messages confirming your order or reporting on the status of your order.

If you register on our site, we give you the option to add your e-mail address to one or more e-mail lists. You may change your preferences or opt out of all e-mails at any time by clicking on the "unsubscribe" link found at the bottom of each e-mail. Note that if you unsubscribe, we may still email you in connection with specific requests from you or regarding issues specific to you.

Please note that, at all times, you are responsible for updating the personal data you provide to us.

Payment for products

If you purchase any products, like any other retailer we will have to provide your payment information to our payment processor and authenticator for payment purposes, and your name and address to the company that ships our merchandise.

Information shared with our business partners

To improve the products and services offered, we may use business partners to help us design and operate our website or provide other services to support the site. For example, we may hire a company to run certain website applications, help us fulfill orders, process payment information, or help us analyze our data. Unless otherwise indicated on our website, if we allow our business partners to access the personal data we collect, it will be for limited purposes and consistent with this privacy policy.

Information shared with our affiliates

We may share your information with our subsidiaries listed at the end of this notice. Unless otherwise indicated, these subsidiaries may use your information for the purposes described in this privacy policy.

Business operations, law enforcement and legal actions

We may release your information without prior notice when we believe it is appropriate to prevent fraud; to comply with law or to cooperate with law enforcement activity or other governmental request; to respond to subpoenas, court orders or administrative agency requests for information; to enforce our policies; to protect the rights, property and safety of our business and of others; or when required or otherwise permitted by law. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our site for illegal reasons. If there is a sale or merger of all or substantially all of the company, division or business unit that operates this site, we may also transfer the information we have collected in connection with such sale or merger.


Legal Basis for Data Processing

Haworth only processes personal data when there is a fair and legal basis for its collection and use, for instance, when the collection of personal data is necessary to enter into a contract, to meet our legitimate interests, to comply with legal obligations or when we have your consent.

The information we collect when we enter into a contract or business relationship with you is necessary to comply with our contractual obligations to you. Without your personal data, we would not be able to provide our goods and services to you. In some cases, we are required to collect personal information to comply with our legal obligations under U.S., EU or other applicable law, as described elsewhere in this notice. For example, some tax, labor, and anti-fraud laws require organizations to collect certain information that may vary depending on local regulations.

When required by applicable law, we obtain your consent prior to sending any direct marketing communications. In any case you can opt-out of these communications any time and free of charge.

When we process your personal data for our legitimate interests, we conduct a balancing test in order to ensure that data subject rights are not overridden. It is in our legitimate interest to process your data to provide our products and services, to improve our products and services, facilitate administrative functions, maintain system security, and conduct product development and research activities, among other purposes.


Our Policy Towards Children’s Personal Data

While our site is available for all to visit, you must be at least 16 years old to register on our website, to purchase products or participate in any of our contests. We will not knowingly collect information about children under the age of 16. If you are under the age of 16, please do not register as a user and do not submit your personal data. If you are a parent who believes that we have collected information about a child under age 16, please contact privacy@haworth.com with your child's name and address, and we will be happy to delete the information we have about your child from our records and, to the extent applicable, provide information in accordance with local laws (e.g. U.S. Children's Online Privacy Protection Act).


Retention periods

Haworth retains personal data for only the length of time required to fulfill the purpose for which the data was collected. We do not keep personal data for longer than is necessary, and what is necessary depends on specific circumstances such as regulations requiring us to retain information for a certain period of time and limitation periods of legal claims.

We use the information that we collect about you only for the purposes for which it is collected and consistent with this Policy. We keep information provided to us for as long as we believe necessary for our business purposes and as permitted by applicable law.

The retention period depends on the context in which we process data such as data from use of our website, or customer data after service with customer has ended. The retention periods are established considering Haworth’s legitimate business purposes and according to local regulations.


Disclosures to Third Parties and processing activities

At times, Haworth engages third party agents, service providers, or other vendors to help accomplish our business objectives. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities.

We engage with third party contractors, service providers and other vendors for some of the following services: Microsoft Dynamics for our Customer Relationship Management (CRM), Adobe for digital transformation, and SAP for dealer orders. We may also give you the option to have your information shared with vendors whose goods we carry so that they can send you coupons or other promotional information in which you are interested.

If the engagement involves the transmission of personal data, Haworth requires the service provider to treat that data consistent with this Policy. A contract to protect the personal data will be executed before any data is disclosed.

In certain circumstances, Haworth may be required to disclose personal data in the context of any sale or transaction involving all or a portion of the business, or when required by law, to protect our legal rights, or in an emergency situation where the security of an individual is endangered. In addition, your personal data may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States.


Security

Haworth is committed to the security, confidentiality and integrity principle. We take commercially reasonable precautions to keep your information secure against unauthorized access and use and we periodically review our security measures. We are committed to processing your data in a secure manner and have put in place specific technical and organizational measures to prevent the personal data we hold from being accidentally or deliberately compromised.

We use commercially reasonable means to protect the integrity of our website and limit access to your personal data. For example, if you purchase any products on our site, we will use a Transport Layer Security (TLS) connection to process your payment information and we will store your personal data on firewall-protected servers. We limit access to your personal data to those who have a legitimate need to use the information. If you have set up a user name and profile, you should be sure to protect your user ID and password to prevent others from being able to access the site in your name. We cannot provide absolute assurances against, and will not be liable for, breaches of confidentiality due to system failures or unauthorized access by third parties.

We also conduct information risk assessments and we include both physical security and IT security in our overall data security approach. We are diligent in selecting vendors or agents that process personal data on our behalf so that they also ensure appropriate technical and organizational measures to protect the data.

Haworth makes reasonable efforts to notify individuals and regulatory authorities, as required by law, if we have reason to believe that personal data or payment card information has been stolen, disclosed, altered or infringed by an unauthorized person. We create and maintain a breach notification and reporting protocol.

We also endorse the concept of privacy by design which is an approach to projects that promotes privacy and data protection compliance from the outset. This means considering the privacy and security implications for any new project or process throughout its lifecycle.

Internet protocol

Haworth uses commercially available security certificates for its website where required. The certificates encrypt all information that is gathered except information not collected through our website such as information provided by e-mail.

Order security

Orders that are placed on the Haworth Store site are from a secure order form using TLS and requires users to provide contact, billing, and payment information. This information is transmitted to a payment provider to authorize the purchase. We do not reveal the payment information during order confirmation. We require each user's phone number to protect Haworth and the user from possible fraud. In order to protect against unauthorized access to your account, it is recommended that you close the browser when you have finished using the site.


Your European data protection rights

If you reside in the territory European Economic Area or Switzerland, Haworth is committed to facilitate the exercise of your rights granted by the European data protection law. You may contact us at privacy@haworth.com at any time to discuss your privacy concerns.

Privacy rights under the European regulation:

  • Transparency and the right to information: we provide notice to our customers, suppliers, website visitors and others of how we use personal data at the time of collecting personal data, or as soon thereafter as possible. We also publish this Policy for a greater transparency.
  • Right to access, rectification, portability, restriction of processing and erasure: we provide data subjects with access to their own personal data where required by applicable law. In addition, we will rectify their personal data when it is incorrect or inaccurate and we will ensure the right to erasure and to restriction of processing when these rights are required by applicable law. When required by applicable law, we will provide a copy of your personal information in a structured, machine-readable format.
  • Right to object and withdraw consent at any time: for all marketing materials, you can opt-out anytime, free of charge. The right to object to other processing activities will be balanced in order to ensure that it is not incompatible with local regulations or the legitimate interests of Haworth.
  • Right to lodge a complaint with a supervisory authority: if you are not satisfied on how we attended your rights and requests, you can lodge a complaint with your local Data Protection Authority.

These requests should be submitted as follows:

  • Opt-out of marketing communications: you can opt-out anytime by clicking on the “unsubscribe” link in our commercial e-mail.  
  • Right to lodge a complaint with a supervisory authority: you may have the right to lodge a complaint with the supervisory authority of your habitual residence or place of work or the place of the alleged infringement.
  • To exercise the rest of your rights: you should send a communication in writing to the contact information listed below and provide information in order to verify your identity. Haworth will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.

International Transfers of Personal Data

If you are located outside the United States and you interact with our website or provide us personal data, then your personal data may be transferred to the United States. If you are based in the European Economic Area or Switzerland, please be informed that the United States is not in the list of countries that the European Commission considers adequate to the protection of personal data. However, we provide appropriate safeguards for your data in the US, as we transfer it based on Standard Contractual Clauses we entered with third parties.


Changes to this Policy

We reserve the right to modify this Policy and related business practices at any time. We will duly inform you of any changes.

Our business and the laws that regulate us change from time to time, and we reserve the right to change this Policy. If we do change this Policy, we will post the revised version on this site. If we change the Policy in a material way, we will provide appropriate notice to you. We will give you the opportunity to express your consent for processing your data for different and new purposes, or we will in any case inform you about the legal basis of such processing other than consent. The time stamp you see on the Policy will indicate the last date it was revised.


Contact Information

At Haworth we are committed to apply this Policy and the accountability principle. If you have any concern or questions about this policy, how your personal data is used, or any rights under the GDPR, please feel free to contact us.

If you have additional questions regarding this policy or any rights under the GDPR, please contact us at any time by, emailing us at privacy@haworth.com or by writing to us at:

Haworth, Inc.
One Haworth Center
Holland, MI 49423-9576
Attn: Legal Department


If you are located in the EU and have any questions about this policy or about our use of your personal information, you may contact our Data Protection Officer or our EU representative using the contact details below:

European Representative: 
Hartwig Nölle
hartwig.noelle@haworth.com 

Data Protection Officer:
Timo Bittner
datenschutzteam@s-con.de

S-CON Datenschutz,
Kriegerstraße 44,
30161 Hannover, Germany. 




Subsidiaries:

| Haworth Inc.; | Haworth, Ltd.; | Haworth Europe SE; | Haworth UK Holdings Ltd.; | Haworth U.K., LLC; | Haworth GmbH; | Haworth SAS; | Haworth Schweiz AG; | Haworth Büromöbel GmbH; | Haworth Ireland Office Solutions Limited; | Haworth Portugal; | Haworth Benelux BV; | Comforto N.V.; | Haworth Hungary  Irodabutor Kft.; | Haworth De Colombia SAS; | Haworth Mexico Servicios S. de R.L. de C.V.; | Haworth Mexico S. de R.L. C.V.; | Haworth (India) Private Limited; | Haworth Japan LLC; | Haworth Australia Pty. Ltd.; | Haworth Malaysia Sdn. Bhd.; | Haworth Industries Sdn. Bhd.; | Haworth Singapore Pte Ltd.; | Haworth Middle East; | Haworth Furniture (Shanghai) Co. Ltd.; | Haworth Hong-Kong, LLC.; | Haworth Furniture (Philippines), Inc.; | Twenty-Twenty PFG design S.L.U.;