So as to leave no doubt, personal data, as defined in myriad law, including but not limited to Article 4(1) of the EU General Data Protection Regulation, is:
“(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Where definitions, as outlined by applicable law from an authority of competent jurisdiction, alter this definition, the broadest definition applies.
Notification of Changes
Pages on the CG360 Web site may include links to third party Web sites. These sites are governed by their own privacy statements, and CG360 is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.
B. INFORMATION WE COLLECT
To open an CG360 account, you must provide your name, company affiliation, address, phone number, and/or e-mail address. This required information is necessary for us to manage your account, and to contact you should the need arise in administering your account.
Web Site Traffic Information
Because of the way that World Wide Web communication standards work, when you arrive at or leave any of the CG360 Web sites, we may automatically receive the Web address of the site that you came from (‘referring site’) or are going to (‘referred site’). We also collect information on which pages of our Web site you visit while you are on the CG360 site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve our service and your experience with CG360. We do not track the Web sites that you visit before or after you leave the CG360 site. To do this we use technology known as cookies.
What are “Cookies”?
Cookies are small text files used by websites and stored on your devices, with your consent, that remember your registered login, help you resume where your last browsing session left off, display pages correctly, and keep track of your preferences within the website.
Our Use of “Cookies”
Cookies allow us to recognize you as a CG360 user if you return to the any of the CG360 sites using the same computer and browser. We use session cookies if and when you log in to your CG360 account by entering your e-mail address and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don’t need to re-enter your password multiple times. Once you log out or close your browser, these cookies expire and no longer have any effect. Cookies are also used to display your e-mail address on our sign-in form, so that you don’t have to retype the e-mail address each time when you log in to your CG360 account. Our cookie files are encoded so that your e-mail address and other information can only be interpreted by CG360.
A visit to a page on our website may generate the following types of cookies:
Registration cookies – These let us know which account you are signed in with and whether or not you are allowed access to a particular service, and they help us associate any comments you post with your username.
Site performance cookies – This is how we remember your preferences for the tools found on our website so you don’t have to reset them each time you visit our site.
Anonymous analytics cookies – These tell us whether or not someone has visited our site in the past so we can track the number of site users and how often they visit for statistics. Note that these cookies can’t be used to identify any individual.
Advertising cookies – We use these to target our advertisement more accurately by telling us whether or not you have seen our ad and how long it is since you have seen it. These cookies store information about what you are looking at on our site, not your personal information.
How to accept, reject or turn off cookies
You can accept or reject cookies on our website via the pop-up cookies banner on our homepage or by emailing our Principal Privacy Officer at firstname.lastname@example.org.
If you would like to turn off cookies from all the websites you visit, you can do so via your browser’s settings. However, the websites you visit will not be able to tell whether you are signed in if cookies are turned off, which means you will not be able to post comments or access certain parts of the website.
Follow the links below to learn about all of your browser’s Cookies settings:
- Cookies settings in Chrome
- Cookies settings in Firefox
- Cookies settings in Safari and iOS
- Cookies settings in Internet Explorer
Note: These links are for reference only and may not work as they not controlled by CG360 and may change based on the company who developed the browser.
How to turn off third-party advertising cookies
CG360 partners with industry leaders to develop its suite of product and services. To inform you of our relationships, from time to time we may display our partners’ branding and collateral. We prohibit the use of advertising cookies by our partners, but links to our partner’s sites may take you to a site that includes their cookies. Some of those websites may include advertisement cookies that anonymously track who has viewed their ad.
The Network Advertising Initiative (NAI), a leading self-regulatory association dedicated to responsible data collection and its use for digital advertising, lets you opt out of third-party advertisements.
Note: This link is for reference only and may not work as they not controlled by CG360 and may change based on the company who maintains their site.
Customer Service Correspondence
If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from CG360 to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our Terms and Conditions agreement. We may, over time, delete these records if permitted by law.
If, at any time you no longer wish to have CG360 use or retain your information, you may withdraw your consent by contacting CG360’s Principal Privacy Officer by email at email@example.com.
C. OUR USE AND DISCLOSURE OF INFORMATION
CG360 does not collect personally identifiable information on individuals for anyone other than the data subject themselves. As such, law and regulation pertaining to such practices do not apply.
CG360 does not transfer data personally identifiable information internationally. As such, law and regulation pertaining to such practices do not apply.
We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order 1) to provide our services, 2) to provide customer service, and 3) to improve our products and services. We give access to individually identifiable information about our users only to those employees who require it to fulfill customer service requests.
For data collected from legal and/or natural persons of participating European Union countries, Article 13(1) of the GDPR provides that:
“(1) Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information: … (c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing; (d) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party”.
and Article 6(1)(f) of the GDPR provides that:
“(1) Processing shall be lawful only if and to the extent that at least one of the following applies: … (f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”
Disclosure to Third Parties
CG360 will not sell or rent any of your personally identifiable information to third parties. CG360 will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.
- We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our Terms and Conditions agreement.
- We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
- We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
- We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in California. However, this aggregated information is not tied to personally identifiable information.
For data collected from legal and/or natural persons of participating European Union countries, Article 13(1)(e) of the GDPR provides that personally identifiable information collected from the data subject, the data controller must provide the data subject with information about “the recipients or categories of recipients of the personal data.” Pertaining thereto, such categories of recipients are noted outlined above. You may exercise any of your rights in relation to notification of recipients, as provided for in EU GDPR 13(1)(e) if you need more detailed information than what is otherwise provided for herein, and such information does not infringe upon the rights of others or is in conflict with any non-disclosure, where such does not contradict governing law, by contacting CG360’s Principal Privacy Officer by email at firstname.lastname@example.org or by way of written notice to:
Principal Privacy Officer
44 Old Ridgefield Road, #216
Wilton, CT USA 06897
Our Contacts with CG360 Users
We may from time to time communicate with users via e-mail to provide requested services, and we may also communicate by phone to resolve customer issues. We use your e-mail address to confirm your opening of a CG360 account, to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.
We also may use your e-mail address to send you other types of communications that you can control, including newsletter, notification of new products or services, customer surveys and notice of special third-party promotions. You can choose whether to receive some, all or none of these communications.
Internet Address Information
We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.
Information Retention and Destruction
Except for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with applicable law and subject to implementation of the appropriate technical and organizational measures required by same in order to safeguard the rights and freedoms of the data subject, personally identifiable information is retained no longer than is necessary for the purposes for which the personal data was processed.
Your Use of Information and Our Services
CG360 does not tolerate spam. Therefore, you may not add a CG360 user to your mail list (email or physical mail) without their express consent after adequate disclosure. We strictly enforce our Anti-Spam Policy!
D. INFORMATION SECURITY
CG360 is committed to handling your customer information with high standards of information security. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards to guard your nonpublic personal information.
The security of your CG360 account also relies on your protection of your password. You may not share your password with anyone. CG360 will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the CG360 Web site.
If you do share your password with a third party for any reason, including because the third party has promised to provide you additional services, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at any of the CG360 websites such as www.absolutelogic.com and changing your Profile settings, and also contact us right away as described in Section F below.
E. ACCESSING AND CHANGING YOUR INFORMATION
You can review the personal information you provided us and make any desired changes to such information, or to the settings for your CG360 account, at any time by logging in to your account on the CG360 Web site. You can also close your account through the CG360 Web site. If you close your CG360 account, we will mark your account in our database as “Closed,” but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.
F. YOUR RIGHTS
Broadly, by law you have the right to:
- the right to access;
- the right to correction;
- the right to removal;
- the right to restrict or object to processing;
- the right to data portability;
- the right to raise a formal complaint with CG360’s Principal Privacy Officer by contacting them at email@example.com; and
- the right to withdraw your use consent.
You have the right to confirmation as to whether or not we process your personally identifiable data and, where we do, access to the personally identifiable data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personally identifiable data concerned and the recipients of the personally identifiable data. Providing the rights of others are not infringed upon, we will supply to you a copy of your personally identifiable data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You may request your personally identifiable data that we store by contacting CG360’s Principal Privacy Officer by email at firstname.lastname@example.org.
You have the right to have any inaccurate personally identifiable data about you corrected and, taking into account the purposes of the processing, to have any incomplete personally identifiable data about you completed.
In some circumstances, without unreasonable delay you have the right to the removal of your personally identifiable data. These include:
- the personally identifiable data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw consent to consent-based processing;
- you object to the processing under certain rules of applicable data protection law;
- the processing is for direct marketing purposes; and
- the personally identifiable data have been unlawfully processed.
However, there are exclusions of the right of removal where processing is necessary including:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation; or
- for the legal purposes.
In some circumstances you have the right to restrict the processing of your personally identifiable data. These include:
- contesting the accuracy of the personally identifiable data;
- processing is unlawful but you oppose removal;
- CG360 no longer has a need for the personally identifiable data for processing purposes, but you require personally identifiable data for legal purposes; and
- you have objected to processing, pending the verification of that objection.
Where this has restricted processing, we may continue to store your personally identifiable data. However, we will only otherwise process it:
- with your consent;
- for the legal purposes;
- for reasons of important public interest; or
- for the protection of the rights of another person.
You have the right to object to our processing of your personally identifiable data, but only to the extent that processing is for legal purposes and or necessary for:
- the performance of a task carried out in the public interest;
- the performance of a task is in the exercise of any official authority vested in us; or
- the purposes of the legitimate interests pursued by us or by a third party.
If the event you raise such objection, we will cease processing of your personal information unless and until we can demonstrate compelling legitimate grounds for the processing which override your objection, or the processing is for legal purposes.
You have the right to object to our processing of your personally identifiable data for direct marketing, at which time we will cease to process your personally identifiable data for these purposes.
You have the right to object to our processing of your personally identifiable data for scientific, historical research or statistical purposes, unless the processing is for the public interest.
To the extent that the legal basis for CG360’s processing of your personally identifiable data is:
- consent; or
- necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out in an automated fashion, you have the right to receive your personally identifiable data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it infringes upon the rights of others.
If you believe CG360’s use of personally identifiable information infringes on data protection laws, you have a legal right to lodge a complaint with an authority of competent jurisdiction who is responsible for the data protection violation you deem to have allegedly occurred.
You may exercise any of your rights in relation to your personally identifiable data contacting CG360’s Principal Privacy Officer by email at email@example.com or by way of written notice to:
Principal Privacy Officer
44 Old Ridgefield Road, #216
Wilton, CT USA 06897
G. CONTACTING US
If you have any questions about this privacy statement you can contact CG360’s Principal Privacy Officer by email at firstname.lastname@example.org, or write us at CyberGuard360, 44 Old Ridgefield Road, #216, Wilton, CT USA 06897,