The following provides examples of the type of information that we collect from you and how we use that information.
|Context||Types of Data||Primary Purpose for Collection
and Use of Data
|Account Registration||We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.||We have a legitimate interest in providing account-related functionalities to our users.|
|Client Information||We collect the name, and contact information, of our subscribers and their employees with whom we may interact.||We have a legitimate interest in contacting our subscribers and communicating with them concerning normal business administration such as subscription services and billing.|
|Demographic Information||We collect personal information, such as your location.||We have a legitimate interest in understanding our users.|
|Employment||If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.||We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations.|
|Feedback/Support||If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.||We have a legitimate interest in receiving, and acting upon, your feedback or issues.|
|Mobile Devices||We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website.||We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.|
|Order Placement||We collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you place an order.||We use your information to perform our contract to provide you with products or services.|
|Website interactions||We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.||We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.|
|Web logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.|
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our websites.
- To provide products and services.
- To improve our services and product offerings.
- To streamline the subscription process.
- To conduct analytics.
- To respond to inquiries related to support, employment opportunities, or other requests.
- To send marketing and promotional materials, including information relating to our products and services.
- For internal administrative purposes, as well as to manage our relationships.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you subscribe to our services, we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your contract or order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
Acquisitions. If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
Other Disclosures With Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
Other Disclosures Without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
Public. Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publically available.
Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, provide technical support, process payments, and assist in the fulfillment of services.
You can make the following choices regarding your personal information:
Access to Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you, in a structured, common and machine-readable format. Note that California residents may be entitled to ask us for a notice describing the personal information (if any) we share with third parties or affiliates for direct marketing.
Changes to Your Personal Information. We rely on you to update and correct your personal information. Our websites allow you to modify or delete your account profile. Note that we may keep historical information in our backup files as permitted by law. If our website does not permit you to update or correct certain information contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.
Deletion of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
Objection to Certain Processing. You may object to our use of your personal information by contacting us at the address described below.
Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
Please address written requests and questions about your rights to email@example.com.
Note that, as required by law, we will require you to prove your identity. We may conduct an identity verification by phone call or email. Depending on your request, we will ask for information such as your name, phone number, email address, and/or billing address. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.
If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
- A signed permission from the consumer indicating that you have authorization to act on the consumer’s behalf.
- If you are a business, proof that you are registered with the Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied.
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
If you subscribe to a CNS service you will be permitted to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account, at the address below.
The following additional information relates to our privacy practices:
Transmission Of Information To Other Countries. We may transmit information between and among our affiliates and locations. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. In order to provide adequate protection for the transfer of your personal information, we rely on the EU Standard Contractual Clauses to facilitate the lawful transfer of content that contains personal information from the European Economic Arena (“EEA”), including the United Kingdom, to outside of the EEA, including the United States, where necessary and as required. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us at the address below.
Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.
Last Updated: July 1, 2020
Effective Date: March 23, 2020