Privacy and Information Security Policy
WHAT PERSONALLY IDENTIFIABLE INFORMATION DO WE OBTAIN FROM YOU? WHEN DO WE OBTAIN SUCH INFORMATION?
If, upon visiting our Website, your use is limited to browsing our informational content, we will not require that you provide us with any personally identifiable information. However, we may request personal information from you at other times. For example:
- Other features of our website or our service may require registration and establishment of a user account, which involves provision of your name, email address, and a password.
- When you use certain features of our service, we collect a variety of other personal information from you. Although this information varies depending on how you use our service, it may include such information as your name, address, phone number, email address or credit card information.
- If you choose to participate in a customer survey conducted by us or by one of our business partners, we may ask for your name, e-mail address and other information as may be required by the particular survey.
- If you report a problem or submit a customer review, we will ask that you provide your name, e-mail address, address, phone number and/or account number. Should you contact us for any reason other than to report a problem and/or submit a review, we may also keep a record and/or copy of your correspondence with us.
HOW DO WE PROTECT THE SECURITY AND QUALITY OF YOUR PERSONAL INFORMATION?
To protect the security and quality of your personal information, we have implemented procedures to maintain accurate, current and complete information as well as to protect your personal information against loss, misuse or alteration when it is under our control. Your personal information is also password protected so that access is limited to yourself and those with whom you share your password, CDP, as well as third party access facilitated by CDP with your prior permission.
HOW DO WE USE YOUR INFORMATION?
Information you share with us will be used in a variety of ways that let us serve you better. We may also use this information to perform administrative, technical, hosting or other functions that help us manage our Website and deliver new functionality to you.
We use your information to: provide you with our services; facilitate and improve our services (including research and marketing purposes) and develop new services; and communicate with you (including administrative messages and promotional communications).
CDP may combine, in a non-identifiable format, the personal information you provide with information from other users to create aggregate data that may be disclosed to third parties for general public health or commercial purposes. Aggregate data does not contain any information that could be used to contact you or identify you.
HOW AND WHY WE SHARE YOUR PERSONAL AND OTHER INFORMATION
While it is fully within your rights to not share personal information, you may not be able to utilize some features of the Website or related services if you choose not to supply personal information.
CDP may use third-party service providers to help us manage and improve the Website and related services. These service providers may collect and/or use your personal or other information to assist us in achieving the purposes discussed above in the section entitled “How Do We Use Your Information?”
We may also share your personal information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
CDP reserves the right (and you authorize CDP) to share or disclose your personal information when CDP determines, in its sole discretion, that the disclosure of such information is necessary or appropriate.
We also may use or share your personal or non-personal information with third parties when we believe, in our sole discretion, that doing so is necessary:
(i) To comply with applicable law or a court order, subpoena, or other legal process;
(ii) To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
(iii) To establish, protect, or exercise our legal rights or defend against legal claims; or
(iv) To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
Finally, your personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change of control, reorganization, bankruptcy, or asset sale. If we sell, merge or transfer any part of our business, part of the sale may include your personal information.
DO WE SELL OR RENT YOUR PERSONALLY IDENTIFIABLE INFORMATION?
No, as a general rule, we do not sell or rent your personally identifiable information to anyone. If and whenever we intend to share your personally identifiable information with a third party (other than as provided herein), you will be notified at the time of data collection or transfer, and you will have the option of not permitting the transfer. However, we may from time to time rent or sell demographic information in the aggregate that does not contain your personally identifiable information.
HOW CAN YOU UPDATE, CORRECT OR DELETE YOUR PERSONALLY IDENTIFIABLE INFORMATION?
You may edit your personally identifiable information and your password at any time by sending an e-mail request to [email protected].
DO YOU HAVE CHOICES ABOUT COOKIES?
Yes, you have several choices with respect to cookies. You can modify your browser preferences to accept all cookies, to notify you when a cookie is set, or to reject all cookies. However, our Web Site uses cookie-based authentication. Accordingly, if you choose to reject all cookies, you may not be able to log onto our Web Site and/or use our services.
WHAT ELSE SHOULD YOU KNOW ABOUT YOUR ONLINE PRIVACY?
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
1. Information We Collect
Through your use of our Website, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Websites has collected the following categories of personal information from its consumers within the last twelve (12) months. Additionally, we have disclosed the following categories of information for a business purpose in the past twelve (12) months:
Disclosed for a business purpose
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||
|G. Geolocation data.||Physical location or movements.||
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||
|I. Professional or employment-related information.||Current or past job history or performance evaluations||
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records||
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
CDP obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from information you submit on the Website during the process of using and paying for products or services.
- Indirectly from you. For example, from observing your actions on our Website.
- From third-party business partners such as social media sites, ad networks, and analytics providers.
2. Use of Personal Information
First and foremost, CDP does not sell and has not sold any Personal Information in the preceding twelve (12) months.
We may use or disclose the personal information we collect for one or more of the following business or marketing purposes:
- To create your account on our Website and let you log in to your account and use the Website services.
- To manage your account, provide you with customer support, and ensure you are receiving quality service.
- To contact you or provide you with information, alerts and suggestions that are related to our products or services.
- For billing-related purposes.
- To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
- To enable and facilitate our products and services.
- To supervise, administer and monitor our products and services.
- To measure and improve the quality, the effectiveness and the delivery of our products and services.
- To market the Website and our products and services to you.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To provide, support, personalize, and develop our Website and our products and services.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
CDP will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. Disclosure of Personal Information
CDP may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may share the minimum necessary personal information with the following categories of third parties:
- Service providers that provide audit, legal, operational, technical or other services for us, such as:
- Customer service
- Technical maintenance
- Monitoring website activity
- Email management and communication
- Database management
- Billing and payment processing
- Reporting and analytics
- Marketing and advertising
- Service providers that provide audit, legal, operational, technical or other services for us, such as:
4. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Request Access to Information
You have the right to request that CDP notify you of the personal information about you that we have collected and used. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we shared that personal information.
- The specific pieces of personal information we collected about you.
- If we disclosed your personal information for a business purpose and identifying the personal information categories that each category of recipient obtained.
Right to Request Deletion of Information
You have the right to request that CDP deletes any of your personal information that we collected about you and retained. Once we receive your request and verify who you are, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights
To exercise the rights listed above, please submit a request in writing to CDP via the contact information listed in the Contact Information section. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.
You may only make a request for access twice within a 12-month period. Your request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify your identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
For Requests to Access, our response will only cover the 12-month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. We will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].
7. Changes to Our Privacy Notice
8. Contact Information
If you have any questions or comments about this Notice, the ways in which CDP collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: [email protected].