Effective Date: 09/10/2021
I. COLLECTION OF INFORMATION
Information you provide directly to us. When you contact us directly, we may collect your contact information—e.g., your name, email address, or other contact information you provide—and any correspondence you send to us.
CATEGORIES AND SOURCES OF PERSONAL INFORMATION
The personal information we collect depends on how you interact with us, the products you use, and the choices you make. We collect personal information about you from different sources and in various ways:
- Contact Information: Depending on the nature of your interaction with us, we collect personal or business information such as name, email address, postal address, and phone number.
- Preferences: We may collect your preferences such as communication, language, and time zone.
- Content of Communications: We will collect your communications with us, such as emails, customer service requests, survey responses, or social media posts or messages.
When you are asked to provide personal information, you may decline. Please be advised if you decline this may affect your functionality with our website and systems.
We may collect the following kinds of information when you use our website:
Information we collect automatically. We may collect certain information automatically when you use our website, such as your Internet protocol (IP) address and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type, operating system, Internet service provider, pages that you visit before and after using our website, the date and time of your visit, information about the links you click and pages you view within our website, and other standard server log information.
II. USE OF INFORMATION
We generally use the information we collect from you to:
- Fulfill your requests for products, services, and information;
- Analyze the use of our website and user data to understand and improve our website;
- For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
- We use the personal information we collect for purposes described in this Policy or otherwise disclosed to you. For example, personal information could be used for the following purposes:
|Purposes of Use||Categories of Personal Information|
|Product Improvement.To improve existing products and services.||Contact Information, Demographics, Preferences, Audio/Visual, Content of Communications, Device Details and Network Information, Digital Activity, Device and Mobile Location, Inferred Preferences|
|Research and Development.To conduct research and develop new products and services.||Demographics, Preferences, Audio/Visual, Content of Communications, Device Details and Network Information, Digital Activity, Device and Mobile Location, Inferred Preferences|
|Business Operations.To operate our business, such as accounting, finance, tax, regulatory compliance, litigation, information security, fraud detection and prevention, supplier and vendor management, human resources, information technology, and improving our internal operations.||Contact Information, Demographics, Payment Data You Provide, Preferences, Audio/Visual, Identification Numbers You Provide, Security, Content of Communications, Device Details and Network Information, Digital Activity, Device and Mobile Location, Inferred Preferences|
- In carrying out these purposes, we combine data we collect from different sources to give you a more seamless, consistent, and personalized experience.
- Finally, we may use de-identified information for any purpose in accordance with applicable law.
III. DISCLOSURE OF INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
- Authorized third-party vendors and service providers.We share your information with third-party vendors and service providers that help us with specialized services, including business analytics and data processing.
- Corporate affiliates. We may share your information with our corporate affiliates.
- Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
- Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of CRADLE, our affiliates, users, or the public.
- With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.
V. YOUR CHOICES
You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). If you choose to refuse, disable, or delete these technologies, some of the functionality of our website may no longer be available to you.
VI. THIRD-PARTY LINKS, CONTENT, AND COOKIES
Some of our website may contain links to content maintained by third parties that we do not control. We may allow third parties to place and read their own cookies, web beacons, and similar technologies to collect information automatically through the sites and online services. We are not responsible for the privacy practices of these third parties, and we recommend that you visit the privacy policies of each website that you visit.
VII. INTERNATIONAL USERS
IX. CALIFORNIA AND EUROPEAN PRIVACY RIGHTS
California Consumer Privacy Act (“CCPA”)
If you are a California resident and the processing of personal information about you is subject to the CCPA, you have certain rights with respect to that information:
Access/Right to Know. You have a right to request that you are provided with the following information:
- The categories and specific pieces of personal information collected about you in the last 12 months.
- The categories of sources from which personal information is collected.
- The purposes for collecting, using, or potentially selling personal information.
- The categories of third parties with which your personal information is shared.
- The categories of personal information disclosed about you for a business purpose. Note that the CCPA defines “business purpose” broadly.
- The categories of personal information sold about you for each category of third party to which the personal information was sold. Note that the CCPA defines “sell” very broadly, and some of our data sharing described in this Policy may be considered a “sale” under that definition. We do not knowingly sell the personal information of minors under 16 years of age without affirmative authorization.
Right to Delete. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions.
Right to Opt-Out From Sales. You also have a right to opt-out from future sales of personal information.
How to Exercise Your California CCPA Rights
- You can exercise your CCPA rights by submitting your request(s) to us via firstname.lastname@example.org.
- If you want to exercise more than one of your CCPA rights, please submit a separate request for each CCPA right, which will help us handle your requests more effectively. Please be aware that we will process your requests in the order we receive them. We will need information from you to process your request so that we can confirm you are a California resident, determine if we have personal information about you, and, for access and deletion requests, verify your identity. We may also need to contact you about your request, and you can choose the contact method you would like us to use.
- Please be aware there might be circumstances where we will not honor your request, as permitted under the CCPA. For example, if we are not able to verify your identity and that you are a California resident, we may not honor your access or deletion request. In addition, we may not delete your personal information if an exception under the CCPA applies.
- You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
- You have a right to not be discriminated against for exercising rights set out in the CCPA.
California Shine the Light
Additionally, under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2020 will receive information regarding 2019 sharing activities).
We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response. Please also note that we may not be required to respond to requests made by means other than through the above designated e-mail address.
California Business and Professions Code Section 22581
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please send a detailed description of the specific content or information you wish to have removed; see How to Contact Us below. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
EUROPEAN DATA PROTECTION RIGHTS
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, personal data;
- If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
- If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
- You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your data after your death.
- You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us via email@example.com with any questions or concerns.
We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.
X. RETENTION OF PERSONAL INFORMATION
We retain personal information for as long as necessary to provide the products and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.
XI. LOCATION OF PERSONAL INFORMATION
The personal information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that the data we collect under this Policy is processed according to the provisions of this Policy and applicable law wherever the data is located.
XII. STILL HAVE QUESTIONS?