Please note that COMPANY is not responsible for the content or privacy practices of third party websites to which https://www.company.com or any other COMPANY website may link to or from. Nor is COMPANY responsible for the privacy practices of any other third party having a relationship with COMPANY, except with respect to their authorized activities in processing data on behalf of COMPANY.
COMPANY collects certain data from visitors to the Site and through email and other interactions and mechanisms in order to use certain features on the Site or to participate in certain activities. This data depends on your interaction with the Site and what functionality you use and may include:
- First and last name
- Postal address
- Phone number
- Fax number
- Email address
- Your password in a hashed form
- Pages visited
- Time, date, and duration of visit
- Browser, device, and operating system you are using
- HTTP headers
- Cookies, web beacons, local and session storage, and conversion tracking
- IP and MAC addresses or other information identifying your computer or device
- Marketing material received
- Files and assets downloaded
- Records of events attended or for which you have registered
- Records of meetings and other personal interactions
- Copies or summaries of communications between you, COMPANY, COMPANY’s partners, and other third parties for the purposes of providing pre- and post-sales support
- Resumes, communications, and other information about yourself if you are applying for employment
- Images and videos of you
- Records of accepting terms and conditions
- Data for financial and transactional purposes between you and COMPANY
- Any other personal data as may be relevant for the purposes below
You may decide whether or not to provide all or part of the requested data, however, if you choose not to provide all or part of the requested information, you may not be able to access certain functions or pages on the Site, and you may not be able to participate in certain events or obtain certain services.
Certain communications, information, and downloadable files that you have submitted to the Site may be available for third parties to view, download, and comment on, depending on the forum in which you decide to share this information.
Use of Data
COMPANY’s purpose in collecting and processing your data is to provide you with access to assets and/or services that you request or enhance your experiences with COMPANY and its products and services. If you have contact with COMPANY as a representative for your organization, COMPANY will process your personal data in order to be able to fulfill COMPANY’s commitment to your organization. COMPANY may also use your data for the following purposes:
- To provide you with personalized access to and tailored content on the Site;
- To enable COMPANY to detect and prevent potentially illegitimate or harmful activities on the Site, including inappropriate comments or unlawfully uploaded files;
To enable you to request and receive information about COMPANY, its events, products and services;
- To enhance your interaction with the Site by storing and subsequently presenting, when you next visit the Site, such data you submit through forms, support services, and other ways for transferring data;
- To facilitate and control access to your personal data;
- To allow you to download documentation and other materials made available by COMPANY or other third parties associated with COMPANY;
- To provide accurate threading in the Site’s comment fields and discussion forums;
- To enable you to register for, and to track your participation in a webinar, workshop, conference, or other event hosted by COMPANY or third parties associated with COMPANY;
- To enable you to submit material for publication on the Site and in other media;
- To provide technical assistance and targeted documentation suited to your particular needs;
- To enable COMPANY to promote its services or the services of its partners and other third parties associated with COMPANY;
- To enable trusted third parties associated with COMPANY to contact you in accordance with your preferences and/or to obtain your consent to communicate with you in accordance with their privacy policies;
- To process an employment application from you;
- To enable COMPANY to evaluate the user experience of the Site and any potential areas for improvement;
- To enable COMPANY to manage its business relationships, such as sales opportunities, commercial offers, and contracts;
- To enable COMPANY to deliver products, or materials through postal services, courier companies, and other means of shipping;
- To enable COMPANY to manage its research and development activities, including bug reports, feature requests, feedback on quality, and performance testing;
- To conduct internal audits and investigations;
- To conduct assessments to identify conflicts of interest;
- To disclose data to governmental institutions or supervisory authorities as applicable in all countries in which COMPANY operates;
- For record keeping and reporting obligations, compliance with government inspections/ audits, responding to requests from government or other public authorities, and responding to legal processes such as subpoenas;
- To establish, exercise, manage, and/or defend against legal claims that COMPANY may have or may be subjected to; and
- Any other purposes associated with the purpose of carrying out the business of COMPANY.
The legal basis on which COMPANY relies for the above use of your data includes:
- Processing of your personal data where you have given consent for one or more specific purposes;
- Processing of your personal data that is necessary for performing a contract to which you are party;
- Processing of your personal data that is necessary to take steps at your request prior to entering into a contract;
- Processing of your personal data that is necessary for COMPANY to comply with a legal obligation; and
- Processing of your personal data that is necessary for the purposes of the legitimate interests of COMPANY or a third party, except where those interests are overridden by your fundamental rights and freedoms which require protection of personal data.
COMPANY allows you to tailor email communications you receive from COMPANY according to preferences, which promote COMPANY products, services, and events. Further, if you do not wish to receive certain emails or any emails at all then you can select the Unsubscribe option through the appropriate links in emails from COMPANY or by contacting the Privacy Manager.
Note, as long as you continue to be a user of COMPANY products or services, or are participating in the process of becoming a user, you are not permitted to unsubscribe from or opt-out of emails and messages regarding your transactional processes, changes, updates, and technical and security notices regarding them, or other emails and messages regarding the support, maintenance, and usage.
COMPANY uses recognized technology and tools to protect the security of your data. Yet, due to the fact that no security system is impenetrable, COMPANY cannot completely and entirely guarantee the data security of COMPANY’s security systems. If these systems are breached and your data is compromised as a result of this, COMPANY will take reasonable steps to investigate the breach and, where appropriate, notify you about which data may have been compromised. COMPANY will also take other steps to address the breach in accordance with any applicable laws and regulations.
Transfer of Data
J.E. Cunningham & Associates, LLC, its affiliates, and subsidiaries are the parties responsible for the management of COMPANY’s jointly-used storage of personal data. Contact information for J.E. Cunningham & Associates, LLC can be found at the bottom of this policy. As a global organization, the data you provide to COMPANY may be transferred to or used by affiliates or subsidiaries of J.E. Cunningham & Associates, LLC and trusted third parties for the purposes described above. J.E. Cunningham & Associates, LLC has established various safeguards to protect your data such as binding corporate rules and/or approved contractual clauses. A copy of these safeguards taken by J.E. Cunningham & Associates, LLC may be obtained by submitting your request to the address identified below for COMPANY’s Privacy Manager.
Data Storage Retention
All data that is collected will be stored only as long as is necessary to accomplish the purpose for which it is collected, or as long as is permitted or required by applicable law. Periodically, COMPANY will review its data processing systems to determine whether or not the purposes for the collection and processing of your data remain valid. That determination will be based on factors that include, but are not limited to, whether or not you are still in contact with COMPANY, whether or not any requests made by you from COMPANY have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between you and COMPANY, and whether or not there is a contractual or legal basis for continuing to retain your data. Based on that review and any notifications received from data subjects, COMPANY will update its systems. For more information on the purpose for which information is collected, please see Use of Data.
Cookies, Web Beacons, Local Storage, and Conversion Tracking
The Site stores cookies and web beacons on your web browser, and makes use of web storage and conversion tracking functionality.
Similar to cookies, web storage is used to store browsing-relevant data on a local database within your browser. It is used to remember the state your browsing history was in the last time you were on the Site. This includes remembering view preferences such as your last sorting of lists, allowing your videos to continue playing from where they last left off, and recovering your in-progress comments or posts on the Site’s forums.
COMPANY may also use web beacons on the Site or in emails sent to you. These are HTML elements, for example images, loaded from a web server passing along an identifier with the load request. Web beacons are used to monitor your navigation when visiting the Site or when opening specific emails.
COMPANY also uses conversion tracking (also known as tracking links) in emails or on the Site or third-party sites to record and transmit which link, element, or component on a web page or in an email was used by you.
Data Concerning Children
COMPANY’s products and services are not marketed to children under the age of thirteen (13) years old. COMPANY does not knowingly collect or process data from any persons under the age of thirteen (13) years old. If COMPANY becomes aware that it has collected personal data from such a child, COMPANY will remove such personal data from their systems.
Third Party Tools, Sites, and Services
COMPANY uses third-party tools including, but not limited to, Google Analytics Demographics and Interest Reports, Hubspot, Wistia, SendGrid, TruConversion, LinkedIn, Facebook, Twitter, and Google+ for the collection, analysis, and/or use of data associated with browsing activity and the type and origin of software and hardware used to engage in that activity. This data is stored on COMPANY’s or the third-party tools’ web servers.
You can prevent these tools from storing and analyzing your browsing history by: disabling cookies and other means of storing data through your browser’s settings; by using the Google Analytics’ Opt-out Browser Add-on available at: https://tools.google.com/dlpage/gaoptout; or by using the disabling features supported by other third-party tools.
COMPANY advertises and markets itself, its products, and its services on different sites across the internet through using cookies and browsing histories collated and applied by third-party tools that include, but are not limited to, Google Adwords. Most of these third-party tools allow you to opt-out of remarketing and tailored online advertising through using the Do Not Track functionality in your web browser or through other methods specified by your browser and/or the respective third-party tool. In particular, you can opt out of Google’s tailored ad serving by visiting Google’s Ads Settings at: http://www.google.com/settings/ads. For more information about the privacy policies of Google, Google Adwords, and Google+, please see: https://www.google.com/intl/en/policies/privacy.
The Site also incorporates “Like” buttons associated with social media sites including, but not limited to, Facebook, Twitter, Google+ and LinkedIn that, if you are logged in to one of these sites, will transfer the link (URL) that you “liked” to your account or page on that respective social media site.
The data collected and stored by these third-party tools is not used by COMPANY to identify you or connect personally identifiable data to you. Further, the providers of these third-party tools are limited in their ability to use and share information they collect by their terms and privacy policies. Aside from the links given above, the tools mentioned in this Policy can be seen at: http://www.google.com/analytics/learn/privacy.html; https://www.google.com/intl/en/policies/privacy; http://www.google.com/intl/en/policies/privacy; https://legal.hubspot.com/privacy-policy; http://wistia.com/privacy; https://sendgrid.com/policies/privacy;; https://www.linkedin.com/legal/privacy-policy; https://www.facebook.com/about/privacy; and https://twitter.com/en/privacy.
For more information on data transfers, please see the Transfer of Data section.
Your Rights to Your Personal Data
You have the right to be informed about the collection and use of your personal data. You have the right to access your personal data and have it corrected if it is wrong or incomplete. You have the right to restrict the processing of your data where the accuracy of your personal data is contested, where the processing is unlawful, and where COMPANY no longer needs the personal data for the purposes for which COMPANY has processed it. You have the right to object to the processing of your personal data and also restrict its processing in those instances where COMPANY undertook processing of it in carrying out a task in the public interest or where necessary for our legitimate interest where there is no compelling reason for its continued processing. You have the right to withdraw consent that you have given to the collection and processing of your personal data at any time. If you do withdraw your consent to the collection and processing of your personal data, that withdrawal shall not affect the lawfulness of any processing by us that is based on the consent you have given before you withdrew it. You also have the right to obtain the deletion of your data when it is no longer relevant to the purposes for which it was collected or processed, when you have withdrawn consent and there is no basis for us to continue processing, when you have objected to further processing and there is no compelling interest for continued processing, and when the data was unlawfully processed.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affecting you, except where there is a lawful basis for continued processing. You have the right to receive personal data in a structured, commonly used, and machine readable form for the purpose of data portability in those instances where COMPANY processes by automated means personal data that you have provided.
These rights may be exercised by using the tools COMPANY offers on the Site or by contacting J.E. Cunningham & Associates, LLC with your specific request through the methods described below. COMPANY will address any such requests in a timely manner. In certain cases, COMPANY may ask you to verify your identity before acting on your request. If you are unsatisfied with COMPANY’s response, you may refer your complaint to the relevant supervisory authority in your jurisdiction.
J.E. Cunningham & Associates, LLC is located at:
J.E. Cunningham & Associates, LLC
Attn: Data Protection
218 Shrewsbury Street
Worcester, MA 01604
Last Revision Date: 10/01/2019