2. Our Principles
CTS has designed this policy to be consistent with the following principles:
Privacy policies should be human readable and easy to find.
Data collection, storage, and processing should be simplified as much as possible to enhance security, ensure consistency, and make the practices easy for users to understand.
Data practices should meet the reasonable expectations of users.
3. Personal Information CTS Collects and How it is Used
As used in this policy, “personal information” means information that would allow someone to identify you, including your name, email address, IP address, or other information from which someone could deduce your identity.
CTS collects and uses personal information in the following ways:
Website Analytics: At present CTS does not collect personal information from visitors to our website.
Log-In Services: When you register to obtain a user account on any of the Services (any such person, a “Registered User”), you will be asked to provide personal information to create your account and establish a password and profile. CTS collects and uses this personal information pursuant to its legitimate interest in establishing and maintaining your account providing you with the features we provide registered users. We may use your email address to contact you regarding changes to this policy or other applicable policies. The name or nickname you provide in connection with your account may be used to attribute you in connection with any content you submit to any Service.
Emails and Newsletters: When you sign up to receive updates or notices from CTS or otherwise subscribe to one of our mailing lists, you will be asked to provide some personal information. CTS collects and uses this personal information pursuant to its legitimate interest in providing news and updates related to service offerings.
Email Analytics: When you receive communications from CTS after signing up for any CTS newsletter, campaign update, or other ongoing email communications from CTS, we may use analytics to track whether you open the mail, click on the links, and otherwise interact with what we send. CTS collects and uses this personal information pursuant to its legitimate interest to provide more relevant news and updates.
Other Voluntarily Provided Information: When you provide feedback to CTS or otherwise submit personal information to CTS, CTS collects and uses this personal information pursuant to its legitimate interest in better providing the Services.
4. Retention of Personal Information
The majority of the personal information collected and used as explained in Section 3 above is aggregated and stored in a central database administered by CTS. CTS aggregates this data pursuant to its legitimate interest in having information stored in a single location to minimize complexity, increase consistency in internal practices, better provide the Services, and enhance the security of the data.
5. Access to Your Personal Information
You are generally entitled to access personal information that CTS may hold and to have inaccurate data corrected or removed to the extent CTS still maintains it. In certain circumstances, you also may have the right to object for legitimate reasons to the processing or transfer of personal information. If you wish to exercise any of these rights, please write to firstname.lastname@example.org explaining your request.
6. Disclosure of Your Personal Information
CTS does not disclose personal information to third parties except as specified elsewhere in this policy and in the following instances:
– CTS may share personal information with our contractors, subcontractors and service providers in order to undertake the activities described in Section 3 and/or provide the Services.
7. Security of Your Personal Information
CTS has implemented reasonable physical, technical, and organizational security measures for personal information that CTS processes against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access, in compliance with applicable law. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. If any data breach occurs, we will post a reasonably prominent notice to the Websites and comply with all other applicable data privacy requirements including, when required, personal notice to you if you have provided and we have maintained an email address for you.
The CTS Login Services account systems have security risks in addition to those described above. Among other things, they are vulnerable to DNS attacks, and using any CTS Login Service may increase the risk of phishing.
The Services are not directed at children under the age of 13. Consistent with the U.S. federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personal information from anyone under the age of 13 without requiring parental consent. CTS specifically prohibits anyone using our Services from submitting any personally identifiable information about persons under 13 years of age. Any person who provides their personal information to CTS through the Services represents that they are 13 years of age or older.
9. Third Party Service Providers
CTS uses many third-party service providers in connection with the Services, including website hosting services, database management, credit card processing, and many more. Some of these service providers may place session cookies on your computer, and they may collect and store your personal information on our behalf in accordance with the data practices and purposes explained above in Section 3.
10. Third Party Sites
11. Transferring Data to Other Countries
If you are accessing or using the Services in regions with laws governing data collection, processing, transfer and use, please note that when we use and share your data as specified in this policy, we may transfer your information to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.
Data transferred from the European Union to the United States or outside the European Union will be consistent with applicable data privacy requirements.
Effective Date: July 1, 2019.