CAMBIA INFORMATION GROUP PRIVACY POLICY

Last modified: May 23, 2018

The purpose of this privacy policy is to set out the principles governing our use of personal information that we may obtain about you. By using the websites, or by registering as a user of the services that we provide, you agree to our use of the personal information that we obtain about you. Please read this privacy policy carefully. Any dispute which may arise over privacy will be subject to this policy, the data protection notice (if any) incorporated into this website and the provisions of Texas law. We may change our privacy policy from time to time. We therefore ask you to check it occasionally to ensure that you are aware of the most recent version that will apply each time you access this website.

Cambia Information Group takes very seriously the privacy of our website users and the security of their personal information. We comply with the General Data Protection Regulation (“GDPR”) and the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union. Cambia Information Group has certified that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield program, and to view Cambia Information Group’s certification, please visit http://www.privacyshield.gov.

For your convenience, this website contains links to a number of other websites. The privacy policies and procedures described here do not apply to those sites; we suggest contacting those sites directly for information on their data collection and distribution policies.

PERSONAL INFORMATION COLLECTION AND USE
Cambia Information Group will only collect personally identifiable data, such as your name or email address, when it is voluntarily submitted to us by you at this website. We may disclose personal information that we collect or you provide as described in this privacy policy:

Except as set forth above, we will not transfer the personal information you provide at this website to any third party. In compliance with the GDPR, we recognize potential liability in cases of onward transfer to third parties of data of EU individuals. 

THE DATA WE PROCESS
You may give us personal information by visiting the website, sending us an email via the Contact Us page, using our services, or by corresponding with us by phone, e-mail, or otherwise. This personal information includes the following data which are referred to in this privacy policy as ‘your data’, ‘your personal data’ or ‘your personal information’:

NON-PERSONAL INFORMATION COLLECTION AND USE
Like many businesses, we monitor the use of this website by collecting aggregate information. We may automatically collect non-personal information about you such as the type of Internet browsers you use, the pages you visit, or the website which directed you to our site. You cannot be identified from this information and it is used only to assist us in providing an effective service on this website.

USE OF COOKIES
Cookies are small files sent to your web browser and stored on your computer's hard drive. This website uses 'session cookies' - temporary cookies that remain in your browser until you leave the website. These allow you to carry information across our site without having to re-enter it; they also enable us to analyze web traffic and improve our online services. They cannot be used to identify you. You may set your web browser to notify you of cookie placement requests or to decline cookies completely. You can delete the files that contain cookies; those files are stored as part of your Internet browser.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. With regard to information that you voluntarily provide to us, you may, of course, simply choose not to provide such information. With regard to cookies, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

ACCESSING AND CORRECTING YOUR INFORMATION
You may also send us an email at cambiainfo@cambiainfo.com 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.

SHARING YOUR DATA
We may share information as discussed in this privacy policy, but we won’t sell it to advertisers or third parties. Others working for Cambia Information Group uses trusted third parties (i.e. IT services, analytics services, etc.) to help us provide, improve, protect, and promote our services. These third parties will access your information only to perform tasks on our behalf in compliance with this privacy policy, and we’ll remain responsible for their handling of your information per our instructions. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. Please remember that their use of your personal information will be governed by their privacy policies and terms.

CHILDREN UNDER 13 YEARS OLD
This website is not intended or designed to attract children under the age of 13. We do not knowingly collect personally identifiable data from or about any person under the age of 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features or provide any information about yourself to us, including your name, address, telephone number, e-mail 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 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at cambiainfo@cambiainfo.com.

SECURITY OF YOUR PERSONAL DATA
We have implemented technologies and policies with the objective of protecting your privacy from unauthorized access and improper use and will update these measures as appropriate as new technologies become available. Unfortunately, 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.

DATA INTEGRITY
We will only process personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal Information is accurate, complete, current, and reliable for its intended use.

ENFORCEMENT
We use a self-assessment approach to assure compliance with this privacy policy and periodically verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Privacy Shield Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using an independent recourse mechanism as a third-party resolution provider.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission.

INDEPENDENT RECOURSE FOR PRIVACY COMPLAINTS
In compliance with the EU-US Privacy Shield, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact:

Cambia Information Group
 Attn: Karlan Witt, Managing Member
 3200 Steck Ave STE 200
 Austin, TX 78757 USA
 512-905-9494
 cambiainfo@cambiainfo.com

Cambia Information Group has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you are an EU Citizen and do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you. As a last resort, EU individuals may seek redress through binding arbitration.

GDPR COMPLIANCE: YOUR RIGHTS – INDIVIDUALS IN THE EUROPEAN UNION
While Cambia is a data processor, if you are an individual in the European Union, you have the right to access, correct, restrict, or erase your personal information stored on our platform at any time. You can also exercise any of these rights at any time by contacting the Controller of the survey or Cambia at cambiainfo@cambiainfo.com. Your rights include the following:

If we have given your personal data to any third parties, we will tell those third parties that Cambia Information Group has received a request to erase your personal data, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold - however, Cambia Information Group will not be in a position to audit those third parties to ensure that the rectification has occurred.

Restricting the use of your data. We only process your personal data where we have the legal basis for doing so. You have the right to ask us to suspend or otherwise restrict the processing of your personal data where:

If we have given the personal data to any third parties, we will tell those third parties that we have received a request to restrict the use of your personal data, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold - however, we will not be in a position to audit those third parties to ensure that the rectification has occurred.

Withdrawing your consent. Where we are relying on consent to process your personal data (for example consent to receive marketing) you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

YOUR RIGHTS – INDIVIDUALS OUTSIDE THE EUROPEAN UNION

Accessing Account Information. We will provide you with the means to ensure that personally identifiable information which is stored on a local encrypted server is correct and current. You may review this information by contacting us by sending an email to our support attendant – cambiainfo@cambiainfo.com.

A Record of Data Transfer. Cambia Information Group will provide the right to request and receive, once a year and free of charge, information about third parties to whom we have disclosed certain types of personal information (if any) about you for our direct marketing purposes in the prior calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to cambiainfo@cambiainfo.com and please include the phrase "Personal Information Privacy Request" in the subject line, the domain name of the website you are inquiring about, along with your name, address and email address. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct marketing purposes.

California Online Privacy Protection Act. As required by the California Online Privacy Protection Act ("California Act") and the California Business and Professions Code, this privacy policy identifies the categories of Personally Identifiable Information (as that term is defined above and in the California Act) that we collect through our website about individual consumers who use or visit our website and the categories of third-party persons or entities with whom such personally identifiable information may be shared. See more about the California Act at http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

WHERE WE STORE AND TRANSFER YOUR DATA
The EU and the United States. We have customers all over the world but to provide you with services, we store, use and transmit information in the United States, the European Economic Area (the “EEA”) and/or Australia.

In relation to personal data of individuals in the European Union, we may share your personal data within Cambia Information Group. This may involve transferring your data outside the EEA. We may also share your data with trusted third parties who assist us in providing, improving, protecting and promoting our Services and this may also involve transferring your data outside the EEA. Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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 post a notice on the website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our website and this privacy policy to check for any changes.

CONTACT INFORMATION
If you have any questions or comments about our privacy policy or wish to submit a complaint, please email us at cambiainfo@cambiainfo.com.