PRIVACY POLICY

Effective as of June 29, 2018

This privacy policy sets out how C² Data Technology uses and protects any information that you provide us.

Introduction

C² Data Technology is committed to protecting your privacy. If we obtain any information by which you can be identified as an individual (“Personal Information”), then you can be assured that it will only be used in accordance with this privacy policy.

Unless expressly stated otherwise, C² DataTechnology is the controller of your Personal Information and responsible for the collection, processing, and disclosure of your Personal Information as described in this Privacy Statement.

This Privacy Statement applies to the following processing activities:

Visiting our websites
Visiting our offices
Receiving communications from us, such as emails, texts, or facsimiles
Submitting information to us via our managed services portal

This End User License Agreement (this “EULA”) is a legal agreement between C² Data Technology, a Delaware limited liability company, and its affiliates or subsidiaries (collectively, “ C²”) and you (either an individual or an entity) (“End User”). Read the following terms and conditions carefully before using the accompanying software. They define your rights and obligations with respect to the enclosed Software (as defined below). If you do not agree to the terms of this EULA, promptly, uninstall and return or destroy the Software. USING THE SOFTWARE INDICATES YOUR AGREEMENT WITH AND ACCEPTANCE OF THE FOLLOWING TERMS AND CONDITIONS. AN INDIVIDUAL WHO DOES NOT HAVE AUTHORITY TO BIND THE ENTITY USING THE SOFTWARE SHOULD NOT USE THE SOFTWARE WITHOUT OBTAINING APPROVAL OF THIS AGREEMENT FROM A PERSON HAVING SUCH AUTHORITY.
YOU UNDERSTAND THAT, IF YOU PURCHASED THE PACKAGE FROM AN AUTHORIZED RESELLER OF C² DATA TECHNOLOGY RESELLER IS NOT C² DATA TECHNOLOGY’S AGENT AND IS NOT AUTHORIZED TO MAKE ANY REPRESENTATIONS, CONDITIONS OR WARRANTIES, STATUTORY OR OTHERWISE, ON C² DATA TECHNOLOGY’S BEHALF NOR TO VARY ANY OF THE TERMS OR CONDITIONS OF THIS AGREEMENT. IN ADDITION, YOU ACKNOWLEDGE THAT, UNLESS OTHERWISE AGREED BY THAT RESELLER IN WRITING OR PROHIBITED BY LAW, THE LIMITATIONS OF CONDITIONS AND WARRANTIES, STATUTORY OR OTHERWISE, AND LIABILITY SET FORTH IN THIS AGREEMENT ALSO APPLY TO AND BENEFIT THAT RESELLER.

What We Collect.

We may collect the following information from time to time: names and company identification; contact information including email address and phone number; other information relevant to customer surveys and/or offers.

If you request customer support, express an interest in obtaining additional information about our services, use our “Let’s Connect” or similar features, register to use our websites, or download certain content, we generally require you to provide us with your contact information, such as your name, job title, company name, address, phone number, email address, or username and password.

If you use and interact with our websites, we automatically collect log files and other information about your device and your usage of our websites through cookies, web beacons, or similar technologies, such as IP addresses or other identifying information, which may qualify as Personal Information. For more information, see the “How we use cookies, web beacons and other tracking technologies ” section below.

If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name, and time and date of arrival.

We may also collect information about you from other sources, including third parties from whom we have purchased Personal Information, and combine this information with Personal Information provided by you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. In particular, we collect Personal Information from the following sources: Business contact information, including mailing address, job title, email address, phone number, ‘intent data’ which is web user behavior data, IP addresses, social handles, LinkedIn URL, and custom profiles from third party data providers for the purposes of targeted advertising, delivering relevant email content, event promotion, and profiling.

What We Do with the Information We Gather

We collect/process your Personal Information for the purposes and on the legal bases identified in the following:

Contracted Services: Where we need to collect and process Personal Information to perform under a contract we have entered into with you and you fail to provide that required Personal Information when requested, we may not be able to perform the contract.
Providing our Websites: We will process your Personal Information to the extent this is necessary for the performance of our contract with you for the use of our websites and to fulfill our obligations under the applicable terms of use/service; where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to operate and administer our websites and to provide you with content you access and request (e.g., download of certain content from our websites);
Promoting Security: We will process your Personal Information by tracking use of our websites, creating aggregated, non-personal information, verifying accounts and activity, investigating suspicious activity, as well as violations of and enforcement of our terms and policies, to the extent this is necessary for the purpose of our legitimate interests in promoting the safety and security of the systems and application used for our websites, and protecting our rights and the rights of others;
Improving our Websites: We will process your Personal Information to analyze trends, track your usage of our websites and interactions with emails to the extent this is necessary for our legitimate interests to develop and improve our websites and to provide our users with more relevant and interesting content;
Managing Users: If you have a services contract with us, we will process your Personal Information by managing your user account for the purpose of performing the contract with you according to any applicable terms of service;
Handling Support Requests: If you fill out a “Let’s Connect” web form, request user support, or if you contact us by other means, we will process your Personal Information for the performance of our contract with you and to the extent it is necessary for the purpose of our legitimate interests to fulfill your request and communicate with you;
Facilitating Payments: If you have provided financial information, we will process your respective Personal Information to check the financial qualifications and collect payments to the extent this is necessary for completing transactions with you under the contract entered into with you;
Managing On-Site Visitors: We will process your Personal Information for security reasons, to register who visited our offices and who signed the non-disclosure agreement that visitors may be required to sign.
Sending Marketing Communications: We will process your Personal Information to send you marketing information, product recommendations, and other non-transactional communications (e.g., marketing newsletters, email, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interests to conduct direct marketing or to the extent you have provided your prior separate consent (please also view “Controlling your personal data” section below to learn how you can control how your Personal Information is processed by us for marketing purposes);
Complying with Law: We will process your Personal Information when cooperating with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of our websites, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with a judicial proceeding, court order or legal process, and/or to respond to lawful requests.

With Whom do We Share Personal Information?

We may share your Personal Information with the following recipients:

Our contracted service providers provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support, and data enrichment; such service providers comprise companies located in the countries in which we operate;
With third–party social networks, advertising networks, and websites, which usually act as separate controllers, so that we can market and advertise on third-party platforms and websites;
In individual cases we may also share Personal Information with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in countries in which we operate who provide consultancy, banking, legal, insurance, and accounting services;
If we are involved in a merger or reorganization, sell a website or business unit, or if all or a portion of our business, assets, or stock are acquired by another company, we may transfer some or all of your Personal Information to such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any such transfer of Personal Information to an unaffiliated third party as processing of your Personal Information will be required for the purposes set out in “What do we do with the information we gather” section above.

Transfer of Information Collected Internationally

Your Personal Information may be collected, transferred to, and stored by us in the United States and by our affiliates in other countries where we operate. Therefore, your Personal Information may be processed outside the European Economic Area (EEA), and in countries that are not subject to an adequate decision by the European Commission and which may not provide for the same level of data protection in the EEA. In this event, we will ensure that such recipient offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

How Long do We Retain your Data?

We may retain your Personal Information for a period of time consistent with the original purpose of collection (see What we do with the information we gather” section above). We determine the appropriate retention period for Personal Information on the basis of the amount, nature, and sensitivity of your Personal Information, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements (such as applicable statutes of limitation).

After the expiration of the retention periods, your Personal Information will be deleted. If there is any information that we are unable for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any future use of the data.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect online against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

While we follow generally accepted standards to protect Personal Information, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us via the “Contacting Us” section below.

How we use Cookies, Web Beacons, and Other Tracking Technologies

We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain Personal Data, from your computer or mobile device as you navigate our websites or interact with emails we have sent you.
We gather certain information automatically via log files. These log files may include your Internet protocol (IP) address (or proxy server), your Internet service provider, mobile carrier, device and application identification numbers, your location, your browser type, the pages and files you viewed, your searches, your operating system, and system configuration information, and date or time stamps associated with your usage. This information is used to help us provide and improve our websites and to guarantee their security.

We use cookies and similar technologies such as web beacons, tags, and Javascript alone or in conjunction with cookies to compile information about the usage of our websites and interaction with emails from us.

When you visit our websites, our servers or an authorized third party may place a cookie on your browser, which can collect information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine areas that you prefer, make your usage easier by recognizing you, and provide you with a customized experience.

We use both session-based and persistent cookies. Session cookies exist only during one session and disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our websites or services. To manage the use of cookies on our websites, consult your settings within your web browser that relate to cookies. Note that opting out of the use of cookies may impact the functionality you receive when using our websites.

We also use web beacons on our websites. We may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. These tracking technologies are used to operate and improve our email communications, our websites and to track the clicking of links or opening of emails.

We may use our own technology or third-party technology to track and analyze usage and volume statistical information to provide enhanced interactions and more relevant communications. In particular, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, the USA as our processor. Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the visitors of the website have come from, and the pages they visit. This information is used by us to improve our websites. To opt out of data collection by Google Analytics, you can download and install a browser add-on, which is available at https://tools.google.com/dlpage/gaoptout?hl=en.

Controlling Your Personal Information

You may choose to restrict the collection or use of your Personal Information in the following ways:

If you have previously agreed to us using your Personal Information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at info@C2datatechnology.com
We will never sell, distribute or lease your Personal Information to third parties unless we are required by law. If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

You have certain rights regarding your Personal Information, subject to local data protection laws. These may include the following rights:

to access your Personal Information held by us;
to rectify inaccurate Personal Information and ensure it is complete;
to erase/delete your Personal Information to the extent permitted by other legal obligations;
to restrict our processing of your Personal Information;
to transfer your Personal Information to another controller (to the extent possible);
to object to any processing of your Personal Information carried out on the basis of our legitimate interests. Where we process your Personal Information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (we currently employ no such automated processing);
to the extent we base the collection, processing, and sharing of your Personal Information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

How to Exercise your Rights

To exercise your rights, please contact us in accordance with the “Contacting Us” section below. We will endeavor to respond to all legitimate requests the 30 days and will contact you if we need additional information from you to honor your request. Occasionally, it may take longer than 30 days, depending upon the complexity and number of requests we receive.

If you have registered for an account with us, you may generally update your user settings, profile, and certain other information by logging into the applicable website with your username and password and editing your settings or profile. Also, to update your billing information, discontinue your account, and/or request the return or deletion of your Personal Information and other information associated with your account, please contact us in accordance with the “Contacting Us” section above.

Your Rights Relating to Customer Data

As described above, we may also process Personal Information in the role of a processor (see “Introduction” section above). If your data has been submitted to us by one of our customers and you wish to exercise any rights you may have under applicable data protection laws, please inquire with our customer directly. Because we may only access our customer’s data upon instruction from the respective customer, if you wish to make your request directly to us, when you contact us please provide the name of the C² Data Technology customer and will endeavor to support them as needed in responding to the request within a reasonable timeframe.

Your Preferences for Marketing Communications

If we process your Personal Information for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located at the bottom of our marketing emails. Additionally, you may unsubscribe by contacting us using the information in the “Contacting Us” section below. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationships with us, such as information about the services you request from us, service announcements, or security information.

Changes to This Privacy Statemen

We will update this Privacy Statement from time to time to reflect changes in our practices, technology, legal requirements, and other factors. If we do, we will update the “effective date” at the top of this Privacy Statement. If we make an update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.

We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing, and sharing of your Personal Information.

Contact US

To exercise your rights regarding your Personal Information, or if you have questions regarding this Privacy Statement or our privacy practices please fill out our Contact Us form or mail us at:

C² Data Technology
50 Milk Street
16th Floor
Boston, MA 02109

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.

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