Privacy and Data Protection PolicyCTL PRIVACY POLICY This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from ctl.net (the “Site”). PERSONAL INFORMATION WE COLLECT When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. We collect Device Information using the following technologies:
Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information”. Some pages may use forms where you may choose to submit your email address and other information to contact CTL or to request information. By submitting this information to CTL, you are agreeing to allow CTL to contact you in the future. When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information. HOW DO WE USE YOUR PERSONAL INFORMATION? We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). We may also use this information to request feedback about your shopping and product experience and to show you future advertising, including retargeting ads based on the how you used our site and what you viewed. SHARING YOUR PERSONAL INFORMATION We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights. CALIFORNIA CONSUMER PRIVACY ACT (CCPA) CTL complies with the California Consumer Privacy Act if you are in California, clicl on the following link: [Do not sell my personal information]. BEHAVIORAL ADVERTISING As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt out of targeted advertising by using the links below:
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. DO NOT TRACK Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser. YOUR RIGHTS If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States. DATA RETENTION When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information. If you would like us to delete your data, contact us at dataprotection@ctl.net. CHANGES We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. CONTACT US For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at dataprotection@ctl.net or by mail using the details provided below: CTL [Re: Privacy Compliance Officer] 9700 SW Harvest Ct. Beaverton Oregon US 97005 ----- DATA PROTECTION POLICY Context and overview Key details
INTRODUCTION Computer Technology Link Corp (DBA CTL) needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law. WHY THIS POLICY EXISTS This data protection policy ensures CTL:
DATA PROTECTION LAW The Data Protection Act 1998 describes how organisations — including CTL— must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The Data Protection Act is underpinned by eight important principles. These say that personal data must:
PEOPLE, RISKS AND RESPONSIBILITIES Policy scope This policy applies to:
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
DATA PROTECTION RISKS This policy helps to protect CTL from some very real data security risks, including:
RESPONSIBILITIES Everyone who works for or with CTL has some responsibility for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. However, these people have key areas of responsibility:
GENERAL STAFF GUIDELINES
DATA STORAGE These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
DATA USE Data is of no unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
DATA ACCURACY The law requires CTL to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort CTL should put into ensuring its accuracy. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
SUBJECT ACCESS REQUESTS All individuals who are the subject of personal data held by CTL are entitled to:
If an individual contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the data controller at dataprotection@ctl.net. The data controller can supply a standard request form, although individuals do not have to use this. Individuals will be charged $15 per subject access request. The data controller will aim to provide the relevant data within 14 days. The data controller will always verify the identity of anyone making a subject access request before handing over any information. OPT OUT If you have not already opted out of receiving marketing communications from CTL and would like to, you can do so at any time by emailing: dataprotection@ctl.net. MANAGE YOUR CTL SUBSCRIPTIONS If you would like to manage the marketing communications that you receive from CTL, you can do so any time by emailing: dataprotection@ctl.net. DISCLOSING DATA FOR OTHER REASONS In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, CTL will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary. PROVIDING INFORMATION CTL aims to ensure that individuals are aware that their data is being processed, and that they understand:
To these ends, CTL has posted this data collection and privacy policy, setting out how data relating to individuals is used by the company. |