Privacy Policy

Introduction

Computer Services, Inc. (“CSI”) respects your privacy and is committed to maintaining robust privacy protections for our users through our compliance with this Privacy Policy. Our Privacy Policy is designed to: (i) help you understand the types of information we may collect from you or that you may provide to us through our Sites (as defined below) and Services (as defined below) and how we collect, use, maintain, disclose, and safeguard that information; and (ii) to assist you in making informed decisions when using our Services.

For purposes of this Privacy Policy, “Sites” refers to any web properties owned and/or controlled by us including, without limitation, our main corporate website at www.csiweb.com (“Website”), our Facebook, LinkedIn, and Twitter pages, and other social media pages and sites.

“Services” refers to CSI’s products and services accessed through the Sites, from which users can download articles and reports, subscribe to receive newsletters and publications, or contact us to learn more about our products and services.

The terms “we,” “us,” and “our” refer to CSI.

“You” refers to you, as a user of our Sites or Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information (as defined below) and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Sites or Services. This policy may change from time to time.

This Privacy Policy covers the following topics:

1. Information We Collect about You and How We Collect It
2. Information Collected Through Automatic Data Collection Technologies
3. The Data We Collect About You
4. How We Use Your Personal Data
5. Purposes For Which We Will Use Your Personal Data
6. International Transfers
7. Data Retention — How Long Will We Use Your Personal Data?
8. How We Use and Share Your Information
9. How We Protect Your Personal Information
10. Biometric Information We Collect
11. Children’s Privacy
12. Links to Other Websites
13. Your State Privacy Rights and Additional Disclosures
14. Privacy Rights of California Residents
15. Privacy EEA Notice Supplement for the Citizens and Residents of the European Economic Area, United Kingdom and Switzerland
16. Changes to Our Privacy Policy
17. Contact Us

1. Related Links

1. Information We Collect about You and How We Collect It

We collect information from and about persons that access or use our Sites or Services. Information may be collected: (i) directly from you when you provide it to us; (ii) automatically when you use the Sites or Services, such information being collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies; or (iii) by third parties. When you access or use our Sites or Services, we may ask you to provide, and we may collect, “Personal Information” and “Non-Personal Information.” “Personal Information” includes your name, postal address, email address, telephone number, country, place of birth, date of birth, job title or position, company or organization name, business address, industry, IP address, education and employment history, or any other information the Sites or Services collect that is defined as personal information under an applicable law, as well as any other identifier by which you may be contacted online or offline. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.

2. Information Collected Through Automatic Data Collection Technologies

As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including: (i) traffic data, location data, logs and other communication data and the resources that you access and use on our Sites; (ii) information about your computer or mobile device and internet connection, including server log data, IP address, operating system information and browser type; and (iii) if you have provided permission through your device to allow us to collect location information, we may obtain your physical location information, from technologies such as GPS, Wi-Fi, or cell tower signals (“Location Information”). You may withdraw your permission for us to acquire your Location Information, but we do not control this process. We use this information to understand usage patterns on our Sites, such as to determine the parts of our Sites visitors find most valuable. The technologies we use for automatic information collection may include:

• Cookies. A cookie is a small file transferred by a web server and stored on the hard drive of your computer or mobile device. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Sites.
• Web Beacons. Pages of our Sites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
• IP Addresses. An Internet Protocol (“IP”) address is a device’s unique numeric address issued under the registration of the Internet Assigned Numbers Authority, by which it can be located within a network. We may record your IP address when you visit our Sites or use our Services. We may use your IP address to help diagnose problems, to administer the Sites, or to protect our Sites and Services.

When you use our Sites or Services, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: (i) analytics companies that evaluate usage of our Sites and Services; (ii) your mobile device manufacturer; or (iii) your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use our Sites and Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, applications, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

3. The Data We Collect About You

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have identified in our Privacy Policy and grouped together as follows:

We do not collect any Special Categories of Personal Data (GDPR Article 9) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic data). Nor do we collect any information about your criminal convictions and offenses, if any, except to the extent that criminal conduct has resulted in your being listed on a restricted party screening list.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with you or a contract between you and a third party under which you have given your consent to providing personal data.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

5. Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

6. International Transfers

We recognize that many countries globally have regulations restricting the flow of personal data across international borders. We have put in place measures to ensure that adequate protection is provided to such data where legally mandated. Whenever we transfer your personal data out of the EEA, the UK or Switzerland, we ensure a similar degree of protection is afforded to it. Please see our Privacy EEA Notice Supplement below for more information.

7. Data Retention — How Long Will We Use Your Personal Data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8. How We Use and Share Your Information

We use information that we collect about you or that you provide to us to:

• Provide you with our Sites and Services and its content, and any other information that you request from us.
• Provide you with information, products or services that you request from us.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you about changes to our Sites or Services.
• Respond to your comments, questions, and requests, and provide customer service.
• Provide news and information we think will be of interest to you.
• Contact you and respond to any communications that you may have had with us.
• Detect and protect CSI against error, negligence, breach of contract, fraud, theft, and other illegal activity, and to audit compliance with our policies and contractual obligations.

9. How We Protect Your Personal Information

To secure customer information sufficiently, we have implemented industry-accepted physical and logical security policies and procedures to safeguard against the unauthorized access, disclosure, alteration or destruction of our customers’ information. However, these measures do not guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of such security measures. Any transmission of personal information is at your own risk. By accessing or using our Sites or Services, you acknowledge that you understand and agree to assume these risks.

10. Biometric Information We Collect

Through various technology features, including but not limited to when you upload a photo through one of our Sites and Services, we may collect data from you that potentially falls under the definitions of “biometric identifiers” or “biometric information” under the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1 et seq., Texas Capture or Use of Biometric Identifier Act (“CUBI”), Bus. & Com. § 503.001 et seq., and other applicable state privacy laws.

The above terms are defined by applicable privacy laws and can vary depending on which law applies to you. However, “biometric identifier” is typically defined as a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. “Biometric information” typically means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual. “Biometric data” typically means data that is generated from the measurement or technological processing of an individual’s physiological, biological, or behavioral characteristics and that identifies a consumer, whether individually or in combination with other data. For purposes of this section, we will collectively refer to this information as “Biometric Information.”

Any collection of Biometric Information is for the sole purpose of performing identity verification. We will not disclose or disseminate any Biometric Information to any entity, other than those contracted third parties that assist us in providing this service to you, or as required by applicable federal, state, or local law, or required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction. We will not “sell” or “share” any Biometric Information as those terms are defined under the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020, Cal. Civ. Code § 1798.100 et seq.

We will retain any Biometric Information for the limited period of time required to provide you with the service, and shall not exceed one year as long as you consent to such retention. After one year, all Biometric Information we have collected from you will no longer be retrievable or readable by our operating systems or applications.

We use appropriate technical, administrative, and physical safeguards to store, transmit, and protect from disclosure any Biometric Information collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same or more protective than the manner in which we store, transmit, and protect from disclosure other confidential and sensitive information.

Biometric Information will only be collected by us with your prior consent. Before using our identity verification services, you will receive a link to a copy of this Privacy Policy. By clicking “I accept” or a similar phrase you consent to our collection and storage of your Biometric Information.

If you are a Washington resident, our collection of Biometric Information as described above may constitute “consumer health data.” Our collection of such data is necessary to provide the service you are requesting. For more information, please see our Consumer Health Data Privacy Policy.

11. Children’s Privacy

CSI is a strong advocate for protecting the privacy of children online. Our Sites and Services are not intended to be used by children, nor do we intentionally collect Personal Information from children under the age of 18. If you are under the age of 18 years, please do not register or otherwise provide information to CSI on a Site. CSI is diligent in its compliance with laws and regulations regarding the privacy of children and complies with the Children’s Online Privacy Protection Act. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact our Data Protection Officer at the address below.

12. Links to Other Websites

As part of the Services, we may provide links to other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Sites and Services. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Sites or via our Services. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

13. Your State Privacy Rights and Additional Disclosures

Depending on the state in which you reside, you may have certain privacy rights regarding your Personal Information. If you are a California resident, please see our “Privacy Notice for California Residents.” For other state residents, your privacy rights may include (if applicable):

• The right to confirm whether or not we are processing your Personal Information and to access such Personal Information and the categories of Personal Information we are processing or have processed;
• The right to obtain a copy of your Personal Information that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
• The right to delete Personal Information that we collected from and/or about you, subject to certain exceptions;
• The right to correct inaccurate Personal Information that we maintain about you, subject to certain exceptions;
• The right, if applicable, to opt out of the processing of your Personal Information for purposes of (1) targeted advertising; (2) the “sale” of your Personal Information (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• The right, at our option, to obtain a list of specific third parties, other than natural persons, to which we have disclosed your Personal Information or any Personal Information;
• If we are required by applicable law to obtain your consent to process sensitive Personal Information, the right to withdraw your consent; and
• The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

We use cookies and other tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. When we engage in those activities, we sell Personal Information (i.e., information from cookies) to third-party advertisers and analytics companies. We do not use personal data subject to applicable state privacy laws for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.

To exercise your rights, please submit a request through our interactive webform available here or by calling us at 1-800-545-4274 extension 3. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision through our interactive webform available here or by calling us at 1-800-545-4274. If you would like to opt out of targeted advertising, you may alter your cookie preferences here.

Oregon Residents:

CSI is registered as Computer Services, Inc., A Corporation of Kentucky with the Oregon Secretary of State. CSI’s address and telephone number may be found in the Contact Us section.

14. Privacy Rights of California Residents

If you are a resident of the State of California, this Privacy Policy includes by incorporation our Privacy Notice for California Residents, that includes additional information required to be provided under California law and can be found here: https://csiweb.com/privacy-policy/privacy-notice-for-california-residents/. The Privacy Notice for California Residents also includes instructions for California residents wishing to exercise their right to submit a data privacy request under California law.

15. Privacy EEA Notice Supplement for the Citizens and Residents of the European Economic Area, United Kingdom and Switzerland

This European Economic Area (“EEA”) Privacy Notice (“EEA Notice”) supplements the information contained in the Privacy Policy of Computer Services, Inc. (“CSI”). CSI provides this EEA Notice to comply with our obligations as a company that may control and/or process personal data as a part of our business activities related to the EEA, the United Kingdom and Switzerland under the EU General Data Protection Regulation (“GDPR”), UK Data Protection Act, and Swiss Data Protection Act, as applicable. This EEA Notice must be read in conjunction with our Privacy Policy to understand all of the terms that apply to the processing of your personal data. Any capitalized term used in this EEA Notice, but not defined will have the meaning ascribed to it in the applicable privacy act or our Privacy Policy.

16. Changes to Our Privacy Policy

CSI reviews this Privacy Policy from time to time to ensure compliance with laws, internal procedures and industry standards. We reserve the right to change this Privacy Policy at any time and may not notify you of such changes. We will, however, post the changes on the Privacy Policy page of our website, located at www.csiweb.com/privacy-policy. The date this Privacy Policy was last revised is identified at the bottom of the page. You are responsible for periodically visiting our Website and this privacy page to check for any changes and/or updates to our Privacy Policy.

17. Contact Us

If you have any questions regarding this Privacy Policy or the practices of our Sites, please contact us at:

Related Links

Biometric Information Privacy Policy for Employees