Effective Date: August 1, 2019.
Please read this Privacy Statement carefully. By browsing our website and expressly consenting where required (for instance, signing up for newsletters and bulletins), you agree to be bound by this Privacy Statement.
Information we collect
CD collects personal data in the course of its business activities, including in connection with some client services. We also collect personal data on certain areas of the Sites when you create a user profile, register for CD newsletters and alerts, participate in our event activities, sign up for any conferences and events, and/or participate in public user posting areas (such as bulletin boards, discussion forums and surveys). The personal data collected varies and may include information that you provide, such as your name, mailing address, e-mail address, telephone number, fax number, and other background information required to process a request or an online payment.
We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected will be associated with any personal data you have provided.
CD may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities (e.g., analysis of client engagement across an industry, markets impacted by regulatory compliance issues, and the like). We will always seek to confirm that the third party has informed you in advance about it’s, and CD’s, use of this data.
Use of information
Our Sites do not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.
Use of information collected via mobile devices
In connection with any mobile applications, CD may use third party service providers to analyze user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, CD may receive reports on some of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles or forms accessed, and other events occurring within our apps. CD will also receive reports on certain errors occurring within mobile applications.
The legal basis by which we process your personal data
Our processing of your personal data for the purposes mentioned above is based:
- in part, on our legitimate interests in promoting and protecting CD, building and maintaining relationships, and providing our services;
- in part, on your consent, for example if you create a user profile, or register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our web-sites;
- in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.
Data recipients and data transfers
Personal data collected in the course of CD business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to CD subsidiaries and affiliates and their personnel.
We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing various information requests, referring you to other sites or services, administering surveys, or communicating with you.
In addition, we may disclose information about you:
- If we are required to do so by law or legal process;
- To law enforcement authorities or other government officials;
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
- If disclosure is necessary to protect the vital interests of a person;
- To protect our property, services and legal rights;
- To prevent fraud against CD, our subsidiaries, affiliates and/or business partners;
- To support auditing, compliance, and corporate governance functions; or
- To comply with any and all applicable laws.
In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. CD is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.
Link to third party sites
The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with CD. The Sites also may allow you to log in to a CD account using certain social network account credentials.
If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.
CD has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized CD personnel and third-party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, CD cannot guarantee that unauthorized persons will not obtain access to your personal data.
CD retains personal data, as necessary, for the duration of the relevant business relationship or as required by law.
The Sites are not designed for or directed at children 13 years of age or younger, and CD does not intentionally collect or maintain personal data about anyone under this age.
Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.
If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at email@example.com. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.
In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.
If you have registered for CD newsletter or alerts, or you receive invitations to surveys, knowledge base materials or events from CD and you prefer not to receive future email communications from us, please review the communications settings in your profile on CD.com, follow the instructions on the page of the Site where you have provided such information, subscribed or registered or write to firstname.lastname@example.org to unsubscribe from all CD communications.
Your California privacy rights
Pursuant to California Civil Code Section 1798.83(c)(2), CD does not share your personal data with third parties for those third parties’ direct marketing use.
Compliance Datalytics LLC
Data Privacy Team
1300 Bristol Ave North, Suite 100
Newport Beach, CA 92660
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