Effective Date: August 1, 2021
All references to CBG include Cook & Boardman Group, LLC, located at 3064 Salem Industrial Drive, Winston Salem, NC 27127, and our wholly owned subsidiaries, unless expressly stated otherwise.
California Residents: If you are a resident of California, you may have additional rights regarding your personal information as set forth in the “Additional Disclosures for California Residents” below.
2. THE INFORMATION WE COLLECT
CBG collects data to provide the Services you request, ease your navigation on our website, communicate with you, and improve your experience using our Services. Some of this information is provided by you directly, such as when you create an account on our website, or purchase a product or service from us. Some of the information is collected through your interactions with our Services. We collect such data using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with the Services. Some of the information is collected from your use of, and interactions with, third parties and us on social media, including but not limited to Facebook, LinkedIn, and Twitter (collectively, “Social Media”).
We also obtain data from third parties or use third parties to assist us with data collection. For example, we may supplement the data we collect as described in this section by purchasing demographic data from other companies. We also use services from other companies to help us determine a location based on your IP address notably to customize certain services to your location. In addition, we utilize third-party services to collect usage data.
The data we collect depends on the Services and features thereof that you use, and includes the following:
2.1. Personal Information
Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household is “Personal Information.” Personal Information does not include:
• Publicly available information from government records.
• De-identified or aggregated consumer information.
In particular, through the Services we collect or may have collected the following categories of Personal Information in the last twelve (12) months. We obtain the categories of Personal Information listed below with the methods described in more detail below.
Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Such as name, signature, 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. Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law. – Age (40 years or older), religion or creed, sex (including gender, gender identity, gender expression, sexual orientation, veteran or military status.
Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity. Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Usage data. We collect personalized information about your use of our Services, to better understand uses thereof and identify potential improvements, as well as to send you promotional communications or offers tailored to your use of our Services and interest thereto.
• Information on the web pages you visit on and off our website and the search terms you enter on our website.
• Information regarding the performance of our Services and any problems you may experience while using them. This information enables us to diagnose problems and offer support in resolution.
• Data about your computer, tablet or mobile phone (“Device”) and the network you use to connect to our website, including IP address, Device type (i.e., make and model, unique Device identifiers, regional and language settings, and other mobile identifiers, such as Apple ID.
Web requests. We collect information regarding every web request sent to the relevant servers. This information is used to provide support, as well as to assess usage and performance of our Services. The data collected for each request can include such things as timestamps, any exception messages, user agent, IP address, and request time and duration.
Geolocation data. Such as physical location or movements. We collect your IP address and infer location such as city or postcode therefrom, when necessary in order to provide you with the Services or to send you promotional communications or for customer relationship management purposes.
Professional or employment-related information. Such as current or past job history or performance evaluations.
Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. For example, we may record customer service calls for quality-assurance purposes.
Inferences drawn from other personal information. Such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Content. We may collect the content of messages you send to us, such as feedback or questions you ask our technical support representatives, when necessary to provide you with the Services you use. We will collect and utilize any data files you send to us for troubleshooting and improving our Services. When you contact us, phone conversations or chat sessions with our representatives may be monitored and recorded in order to improve our services, facilitate the processing and resolution of your request or complaint.
Screen and Video Sharing. If you use Screen and Video Sharing Features (“Sharing Features”) in connection with the Services we may have access to: the content of the computer screens you share (including all items on your computer desktop), videos transmissions of the rooms and objects you share (including all items with in the rooms), and files or other documents you share. We use information provided though the Sharing Features to provide you with customer assistance. We do not store photographs or video transmissions that you provide through the Sharing Feature or share such information with third-parties other than described below. It is your responsibility to ensure that the rights of others are not infringed upon when using the Sharing Feature.
Surveys and Studies. We may ask you to participate in a survey or study; and may request information from you. Participation is voluntary, and you have the choice of whether to disclose any requested information.
2.2. Automatically Collected Usage and Device Information.
Similar to other websites, we use tracking technologies to automatically collect certain technical information from your web browser, mobile, or other device when you visit our Services. This data may include, without limitation, your IP address, browser type and language, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of your visits. Our collection of this data, described in more detail below, allows us to provide more personalized services to you and to track usage of the Site.
CBG automatically derives and collects certain data based on your interactions with the Services using cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to improve your online experience and to collect information about use of our Services.
We may combine the information we collect via Cookies with Personal Information that we have collected from you to learn more about how you use our Services in order to improve them.
We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our websites can be grouped into the following categories:
• Strictly Necessary: These Cookies are necessary for the websites to work properly. They include any essential authentication and authorization Cookies for our websites.
• Functionality: These Cookies enable technical performance and allow us to “remember” the choices you make while browsing our websites, including any preferences you set. They also include sign-in and authentication cookies and identifiers that enable you to return without additional sign-in.
• Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the websites or utilize the Services running on your device. They help us understand which areas you use and what we can do to improve them.
• Targeting: These Cookies are used to deliver relevant information related to our websites to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our websites. Some of these types of Cookies on our websites are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to our websites.
To learn more about cookies and web beacons, visit www.allaboutcookies.org.
B. Pixels (aka web beacons/web bugs/java script).
CBG web pages may use other technologies such as web beacons to help deliver cookies on our websites and count users who have visited those websites. We also may include web beacons in our promotional email messages or newsletters to determine whether you open and act on them as well as for statistical purposes.
In addition to standard Cookies and web beacons, our services can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally.
2.3. Social Media
2.4. Third Party Analytics Providers
3. HOW WE USE PERSONAL INFORMATION
We will only use your Personal Information when the law allows us to. We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
CBG uses information that we collect from customers and visitors for the purposes of:
• Providing our Services;
• Processing payments;
• Providing ongoing support;
• Evaluating you for a job or internship;
• Communicating with you, including promotional communications and customer relationship management (“CRM”);
• Providing information about other Services;
• Helping us run our company, for example to improve our Services or our security, train staff or perform marketing activities, including CRM;
• Complying with our legal obligations; and
• Accounting and other administrative purposes.
3.1. Examples of How We Use Personal Information
Examples of the uses of information include:
Providing Services. We use data to carry out your transactions with us and to provide Services to you. Often, this includes Personal Information such as email, name, job title, company, and address. We may collect additional information when you register to use the Services, including contact information and credentials. We may use this data to diagnose and address problems and provide other support services.
Improving Product and Services. We use data to continually improve our Services, including adding new features or capabilities. Data is collected throughout your interactions with our Services that enable us to understand customer usage and tailor future capabilities.
We track general, non-personalized information (e.g., operating system, browser version and type of device being used) to know how many people visit specific pages of our Services or utilize specific areas of our Services so that we may improve those Services. We may use your IP address to customize services to your location, such as the language displayed on our Services.
Please note that we use IP addresses on a highly restrictive basis to analyze trends, to administer the site, and to collect general information for aggregate use.
Marketing and Event Communications. We use Personal Information to deliver marketing and event communications to you across various platforms, such as email, direct mail, social media, and online via our Services.
If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. For information about managing email subscriptions and promotional communications, please visit the Your Rights Regarding Your Personal Information section of this privacy statement. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
Processing Payments. If you make a payment to CBG, we will ask for payment information and other information requested for processing your payment.
3.2. Interest-Based Advertising and Retargeting
These Advertisers use this information for “interest-based advertising” or “retargeting” i.e. to deliver future targeted advertisements to you, which may include displaying ads on the websites of unaffiliated third parties. In addition, Advertisers may use the information collected from these types of Cookies and similar technologies for a variety of other purposes, including (a) in conjunction with other advertising that appears on third-party websites; (b) for reporting website traffic, statistics, advertisement data, and other interaction with ads and the websites on which they are served; and (c) to measure the effectiveness of web-based and e-mail advertisements.
3.3. Use of Non-Personally Identifiable Information
We may use non-personally identifiable information, such as anonymized and/or aggregated Services usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Services, including to develop new features, functionality, and services, to conduct internal research, to better understand usage patterns, to resolve disputes, to troubleshoot problems, to fulfill user requests, or for security and compliance purposes. Any non-personally identifiable information that is combined with Personal Information will be treated by us as Personal Information.
4. HOW WE SHARE PERSONAL INFORMATION
We may provide your Personal Information for a business purpose to:
• CBG-controlled affiliates and subsidiaries, located in and outside your country or region;
• outsourced service providers who perform functions on our behalf, located inside or outside of your country or region. For example, when you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction;
• our authorized agents and representatives, located inside or outside of your country or region, who sell products or provide services on our behalf;
• anyone expressly authorized by you to receive your Personal Information;
• anyone to whom we are required by law to disclose Personal Information, upon valid and enforceable request thereof.
We will access, disclose and preserve Personal Information when we have a good faith belief that doing so is necessary to:
• comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies, upon valid and enforceable request thereof; or
• operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks.
Please note that some of our Services may direct you to services of third parties whose privacy practices differ from CBG’s. If you provide Personal Information to any of those services, your data is governed by their privacy statements or policies. Cook & Boardman Group, LLC and their subsidiaries are not responsible for the privacy practices of these other websites. Please review the privacy policies for these websites to understand how they process your information.
5. HANDLING OF PERSONAL INFORMATION
5.1. Security of Personal Information
CBG is committed to protecting the security of your Personal Information. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal information. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.
These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.
You are responsible for maintaining the security of your account credentials for the Services. CBG will treat access to the Services through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
If we become aware of a breach that affects the security of your personal information, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, CBG will provide any such notice that CBG must provide to you at your account’s email address. By using the Services, you agree to accept notice electronically.
5.2. Storage and Transfer of Personal Information
CBG also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal information within CBG or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal information is processed, secured, and transferred according to applicable law.
If you would like to know more about our data transfer practices, please contact our Legal Department at firstname.lastname@example.org.
5.3. Retention of Personal Information
CBG retains personal information for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g. statute of limitations). If your personal information is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.
6. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
CBG respects your right to access and control your personal information. You have choices about the data we collect. When you are asked to provide personal information that is not necessary for the purposes of providing you with our Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features or Services.
We aim to keep all personal information that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details and this can be easily accomplished using the Manage Account section. However, if you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact us at email@example.com.
Access to personal information: In some jurisdictions, you have the right to request access to your personal information. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
If you are a corporate user of our Services (which means your employer is a CBG customer of such Services): please first request access to your personal information with your employer. Your employer will then be in touch with us with respect to your request.
Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion of your personal information. Please note that such a request could be refused because your personal information is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.
Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about CBG products, services and events that may be of interest to you, including our newsletter.
E-mail communications you receive from CBG will generally provide an unsubscribe link allowing you to opt-out of receiving future e-mail or to change your contact preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
You can also request changes to your account by emailing CBG at firstname.lastname@example.org.
How to Control and Delete Cookies: Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across these environments.
If you are using a mobile device to access our websites, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device.
Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the websites may not operate properly, and you may not have access to our websites available through the websites. CBG is not liable for any impossibility to use the websites or degraded functioning thereof, where such are caused by your settings and choices regarding cookies.
Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including CBG, do not respond to DNT signals.
Interest-Based Advertising: If you would like more information about Advertisers’ practices, please see http://optout.aboutads.info/#!/.
You can also learn more about our current Advertisers and review your opt-out options on their websites:
You can generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (DAA) by visiting the opt-out pages on the NAI website (http://optout.networkadvertising.org) and DAA website (http://www.aboutads.info/choices/).
7. EXTERNAL LINKS
To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the websites. We currently use, and may in future use content from websites such as Facebook, LinkedIn and Twitter. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these cookies are used and how you can control them.
8. CHILDREN’S PRIVACY
THE SERVICES ARE NOT INTENDED FOR CHILDREN
You must be at least the age of majority in your place of residence to use the Services. The Services are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Services.
California Minors: While the Services is not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: email@example.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. Removal of your Personal Information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.
10. QUESTIONS OR COMPLAINTS HANDLING
11. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
11.1. Use of Personal Information
We 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.
11.2. Sharing Personal Information
11.3. 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.
A. Right to Access Specific Information and Data Portability Right
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, 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 or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.
B. Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
C. Exercising Your Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
For submissions via email please use the downloadable Verifiable Consumer Request Form.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make such a request for access or data portability twice within a 12-month period. The verifiable consumer 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, and 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 verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer 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. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, 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 verifiable consumer 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.
11.5. California Shine the Light Law
California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to firstname.lastname@example.org or write us at: Cook & Boardman Group, LLC, 3064 Salem Industrial Drive, Winston Salem, NC 27127
11.6. Contact Information