WEBSITE PRIVACY POLICY

Effective: 01.01.2020

Last Reviewed on: 7.30.2020

1. Introduction

At Concord Technologies Inc. (“Concord” or “we”), protecting your privacy is extremely important to us. As we provide privacy-first data solutions that protect and reward people and the brands they engage with, we know how important it is to be able to understand what information is being collected about you, what it is used for, and how it is protected.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.concord.tech (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy does not apply to the Concord services (“Service”) which are provided to you via our Concord applications. For users of the Concord Service, please see the Software Privacy Policy and Software Terms of Service.

This policy applies to information we collect:

  • On this Website;
  • In email or other electronic messages between you and this Website; or
  • When you interact with our advertising and applications on third-party websites and services.

It does not apply to information collected by:

  • Us offline;
  • Via the Service; or
  • Any third party that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using this Website, you agree to this privacy policy.

This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

2. Information We Collect About You & How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name and e-mail address (“personal information”); and
  • About the website from which you visited us from, the parts of our site you visit, the date and duration of your visit, your anonymized IP address, information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) you used during your visit, and other information about your use of the Website or your interaction with our email campaigns.

We collect this information:

  • In the case of personal information, directly from you when you provide it to us;
  • With respect to other information, we collect this information automatically as you navigate through the Website or interact with our email campaigns. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us  

When you provide personal information to us by signing up to receive communications from us, we will use that information to communicate with you about our services. We may associate information that we collect automatically with your personal information.

Information We Collect Through Automatic Data Collection Technologies  

As you navigate through and interact with our Website or click on an email from us, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically does not include personal information, but we may maintain it or associate it with personal information.

It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns;
  • Store information about your preferences, allowing us to customize our Website according to your individual interests; or
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser 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 Website. 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 Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our the Website [and our e-mails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or that you provide to us.

We may also use these technologies to collect information about your activities over time and across third-party websites, Services, or other online services (behavioral tracking). Some browsers have incorporated ‘Do Not Track’ features. Most of these features, when turned on, send a signal or preference (a "DNT Signal”) to the web sites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret DNT Signals, nor a common definition of tracking, we do not currently respond to DNT Signals across all browsers, although we do attempt to respond to certain browsers DNT Signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

3. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you;
  • To provide you with information or services that you request from us;
  • To provide you with information about our services;
  • To fulfill any other purpose for which you provide it;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To notify you about changes to our Website or any products or services we offer or provide though it;
  • In any other way we may describe when you provide the information; or
  • For any other purpose with your consent.

4. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or that you provide:

  • To our subsidiaries and affiliates;
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
  • To fulfill the purpose for which you provide it;
  • For any other purpose disclosed by us when you provide the information; or
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request; or
  • To enforce or apply our terms of service or other agreements.

5. Choices About How We Use & Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies & Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our services, you can opt-out by emailing privacy@concord.tech. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

California residents may have additional personal information rights and choices. Please see the “For California Residents – Accessing & Correcting Your Personal Information” section below for more information.

6. Accessing & Correcting Your Information

You may also send us an email at privacy@concord.tech to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional personal information rights and choices. Please see the “For California Residents – Accessing & Correcting Your Personal Information” section below for more information.

7. For California Residents –Accessing & Correcting Your Personal Information

Pursuant to Section Cal. Civ. Code § 1798.140(c), we are not required to comply with the California Consumer Privacy Act (“CCPA”). However, due to our commitment to privacy and transparency, we strive to follow CCPA guidelines.

Please note that, because we are not required to comply with the CCPA, we expressly disclaim any liability to you arising from or related to our failure to comply with the CCPA.

If you are a resident of California, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting or selling that personal information;
  • The categories of third parties with whom we share that personal information;
  • The specific pieces of personal information we collected about you (also called a data portability request); or
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

If you are a resident of California, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug or identify and repair errors that impair existing intended functionality;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If you are a resident of California, to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: Calling us at 833-444-2673 or emailing privacy@concord.tech.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not (a) deny you goods or services, (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (c) provide you a different level or quality of goods or services, or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

8. Data Security

The transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

9. Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.

10. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address you provided us. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

11. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, please email us at privacy@concord.tech or call us at 833-444-2673.