APPLICABILITY OF THIS POLICY
This privacy policy applies to Civicom's registered users only. It does not apply to other websites that may be linked to our site. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
INFORMATION WE COLLECT AUTOMATICALLY
When you visit our site, your browser automatically sends us an IP (Internet Protocol) address and certain other information (including the type of browser you use).
A cookie is a small text file placed on the hard drive of your computer that allows our website to recognize you. The cookies we use do not themselves collect personal information about you or provide us with any way to contact you; they simply assign a randomly generated number to your computer. The cookies also do not extract from your computer any information regarding other Internet sites or your surfing activities. Please see Cookies for Registered Users for an explanation of why we need cookies to serve our customers and Cookies for First-Time or Casual Visitors for what cookies do for those who are not yet our customers.
COOKIES FOR REGISTERED USERS
If you are a registered user of our Service, we need cookies so that we can know who you are. Cookies allow us to correlate the arbitrary designation assigned to your computer by the cookie with your telephone number, which we maintain securely on our database. This allows us to provide you with our Service without requiring you to transmit personal information (such as your telephone number) to us insecurely over the Web. Without cookies, we have no safe way of connecting your calls.
COOKIES FOR FIRST-TIME OR CASUAL VISITORS
If you are not yet a Civicom customer, the use of cookies is not required. However, like many website operators, we use cookies to enhance your experience on our site, including allowing our server to recognize your computer and thereby avoid sending you repetitive messages or advertisements. Most commonly used browsers allow you to disable cookies should you so choose. Please consult your browser help file for more information should you wish to do so.
TRAFFIC AND SITE USAGE DATA
You also should be aware that we collect certain usage information about our website, such as the number and frequency of visitors to certain parts of the website. This allows us to improve our website in ways that our visitors will find most useful. These data are collected and used only in aggregated form; they do not include any personal information.
ACCOUNT AND TELEPHONE INFORMATION
If you choose to open an account with us, we will ask that you provide us with certain personal information (such as name, address, billing information, and the like), along with your telephone number. We will not disclose that information to any third parties except as set forth below in How We Use Information You Provide Us. Similarly, when you use your Service, from time to time you, of course, will provide us with the telephone numbers of others whom you are calling, whether or not they also are account-holders. You are not required to provide the name or any other identifying information of any non-account-holder whose number you provide us, and we retain the telephone numbers themselves only for purposes of the call itself and our billing records. As with your own information, we will not disclose these numbers to any third parties except as set forth below in How We Use Information You Provide Us.
HOW WE USE INFORMATION YOU PROVIDE US
We may use any information you provide internally for any business purpose. If you have an account with us we may access your account (1) to provide you with services requested; (2) for billing purposes; (3) to conform to legal requirements or comply with legal process; (4) to protect or defend the rights and property of Civicom; (5) to enforce the Terms of Service Agreement; or (6) to act to protect the rights of our account holders or others. We also may supply your telephone number, call information (including the numbers you are calling), or electronic mail address to third-party service providers such as Internet service providers, your telephone company, and others, but only for the purposes of providing our Service to you. Civicom, its employees, or its agents will access your account with us, and use the information contained therein, only for legitimate business purposes as set forth above, or to respond to service or technical issues.
In addition, with the exception of Respondents in Marketing Research Studies, to whom this paragraph does not apply, we may use the information you provide to improve our products and services; to periodically send promotional emails about new products, special offers or other information which we think you may find interesting, and or to customize the website, using the phone number and or email address which you have provided. You may opt out of receiving promotional information from us at any time by requesting to do so by clicking on the relevant link on promotional communications we send to you.
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place certain physical, electronic, and managerial procedures to help safeguard the information we collect online. We use industry-standard, established security measures in our physical facilities and computer systems, databases, and communications networks that are designed to protect information contained within our systems from loss, misuse, or alteration. However, please be aware that it may be possible for others to read messages that you send to us over the Internet, so do not send by email any information that you would like to keep confidential. You can contact us for methods of providing your data more securely.
PERSONALLY IDENTIFIABLE INFORMATION FOR
MARKETING RESEARCH RESPONDENTS
The Civicom Marketing Research Services Unit of Civicom is engaged in facilitating marketing research services to clients who utilize Respondents who are individuals, members of the public, participants in research panels, or professionals in designated fields of interest to marketing researchers for the purposes of conducting market research. Personally identifiable information (PII) is any information that can be used to identify an individual person. From time to time, Civicom is in receipt of this type of data, on a study by study basis, in order to facilitate the client research project. Where personally identifiable information is stored or processed, there are controls to ensure that it is adequate, relevant and not excessive for the purposes for which it is collected; kept confidential; processed fairly, used only for specified, explicit and legitimate purposes; held in a format that permits identification of individuals for no longer than is necessary; and only provided to third parties that can demonstrate compliance with legal and regulatory requirements for handling personally identifiable information. We strive to manage personally identifiable information in accordance with relevant legislation, such as the EU Safe Harbor Directive on Data Protection or the US Health Insurance Portability and Accounting Act (HIPAA).
Visiting and using our website, and/or becoming a Civicom Registered User, or participating in a marketing research study facilitated by Civicom are all voluntary activities. Accordingly by doing so, you acknowledge that you accept the methods in which we manage data.
UPDATES, CORRECTIONS AND CHANGES
Contact us at the address indicated below if you would like to access or update your previously provided account or other personal information.
You may contact us with any questions or concerns regarding this Policy. You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of this information please write to Civicom, Inc., P.O. Box 4689, Greenwich, CT 06831 at
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CHANGES TO OUR PRIVACY POLICY
Civicom reserves the right to change or update our policy at any time by providing updated information on this page.
CIVICOM AFFIRMATIVE COMMITMENT TO THE SAFE HARBOR FRAMEWORK(S)
Civicom complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Civicom has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Civicom's certification, please visit
http://www.export.gov/safeharbor/
ENFORCEMENT AND RESOLUTION
Civicom utilizes a combination of self-assessment and audit approaches to assure compliance with this privacy policy. We periodically verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the principles set forth herein. We will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the principles of managing personally identifiable information (PII).
If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using eTrust Privacy Services as a third party resolution provider. You can reach eTrust's privacy complaint system at the following URL: http://www.etrust.org/complaint/raise_privacy_complaint.php
We self-certify compliance with:
Last Revision Date: April 3, 2014
