Consortium | Privacy Policy

Updated Date: 06/28/24

This privacy policy (the “Privacy Policy”) discloses the privacy practices for Consortium Networks and explains why and how we collect, use, and share information about visitors to our website, www.consortium.net, and any other websites or pages that link to this Privacy Policy (collectively, the “Site”); and individuals who inquire about and/or use our various services (the “Services”).

This privacy notice applies solely to information collected by this website. It will notify you of the following:

What personally identifiable information is collected from you through the website, how it is used and with whom it may be shared.
What choices are available to you regarding the use of your data.
The security procedures in place to protect the misuse of your information.
How you can correct any inaccuracies in the information.

Information Collection, Use, and Sharing

We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone.

Information we collect

Through our website, we only collect name and contact information. WE DO NOT collect credit card information, Social Security and/or other Personally Identifiable Information (PII).

We also automatically collect statistical data when you visit our website. This may include information about your device, the time you spent on the website and the pages you visited.

Like most companies we use cookies and similar technologies to collect aggregate (non-personal) information about website usage by all of our visitors and to help us remember you and your preferences when you revisit the website. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology that assists in the functioning of the website. These cookies usually are erased when you close your browser window. Further general information about cookies and how they work is available at www.allaboutcookies.org.

We may allow selected third parties to place cookies through the website to provide us with better insights into the use of the website or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.

We use technology that recognizes a “do-not-track” signal from your web browser except as provided in this Privacy Policy.

How we use information

We use the collected information for our general commercial purposes such as to improve our website, grow our business and to offer our own or third-party products or services that we think you may find of interest. We will use your information to facilitate response to your inquiries or to provide information on products or services to you. Disclosing information

We will not share your information with any third party outside of our organization, other than as disclosed in this Privacy Policy. We may reveal information about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.); (4) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); (5) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); or (6) as otherwise described in this Privacy Policy.

We do not disclose your information to third parties for their marketing purposes.

Your Access to and Control Over Information

You may opt out of any future promotional emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending emails about your account or your transactions with us.

You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the website may be impaired and certain features may not function at all. You can do the following at any time by contacting us via the email address or phone number provided below:

See what data we have about you, if any.
Change/correct any data we have about you.
Have us delete any data we have about you, with certain exceptions.
Express any concern you have about our use of your data.

Security

We use reasonable physical, administrative and technical safeguards to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.

Wherever we collect sensitive information, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the Web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to your information. The computers/servers in which we store sensitive information are kept in a secure environment.

Data Processing and Cross-Border Data Transfers

Our website is maintained on servers located in the United States, and personal information submitted is stored on our servers in the United States. If you are visiting our website from outside the United States, please be advised that your information is transferred to our U.S. servers. Disclosing your personal information to us pursuant to this Privacy Policy is at your own risk. We strive to comply with laws of jurisdictions in which we maintain operations but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information.

CCPA Notice to California Residents

This CCPA Notice to California Residents is part of the Privacy Policy and applies to information that we collect from or about California residents offline as well as online.

The California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”) provides certain verified California residents with the rights described below. For details on how to exercise these rights, please see below. We will not discriminate against you as a result of your exercise of any of these rights. For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. CCPA Rights

The CCPA provides California residents with the following rights regarding their personal information.

A. Information Access and Portability Rights

As a California resident you have the right to request that we disclose certain information upon request about our information collection and disclosure practices. You also have the right to request a copy of the specific pieces of personal information we collected about you. You may make Information Access Requests up to twice during a 12-month period. Once we receive and confirm your verifiable request, we will disclose to you:

The categories of personal information we collected about you, the sources of the information, our business or commercial purpose for collecting the information and whether the information was disclosed for a business purpose, shared or sold.
The categories of information we disclosed for a business purpose and the categories of information we sold or shared during the prior 12 months along with the categories of recipients of such information.
The specific pieces of personal information we collected about you during the prior 12 months, or, at your option, since January 1, 2022. Please note that this disclosure will not include data generated to help ensure security and integrity or as prescribed by regulation. We will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

B. Information Deletion Rights

California residents have the right to request that we delete any of your personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. You may make deletion requests at any time. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities and to help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s ability to complete such research, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it

C. Information Correction Rights

California residents have the right to request that we correct information that we hold which is inaccurate. We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections. In some cases, for instance if you have an account with us, you can update your information by logging into your account. You can make information correction requests at any time.

D. Opt-Out Rights

Do Not Sell My Personal Information. If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

We do not sell your personal information.

Do Not Share My Personal Information. You have the right to opt out of having your personal information shared with others for cross-context or behavioral advertising purposes. This does not include using your interactions with us or information that you provide to us to select advertisements to show you.

We do not share your personal information with third parties for cross-context or behavioral advertising purposes.

Limit Processing of Sensitive Personal Information. You have the right to tell us not to process or disclose Sensitive Personal Information for any purpose other than the purposes disclosed at or before the time we originally collected it.

We only process Sensitive Personal Information for the purposes permitted by the CCPA.

Information Collected, Sources, and Business Purpose for Collection

The following table lists the categories of personal information defined in the CPRA, whether we have collected information in the category during the past 12 months, the sources of the information, and the business purposes for which we collect and use the information. The categories of information include information we collect from our website visitors, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.

Category	Examples	Collected from employee/applicants
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories Protected under the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected anti-discrimination classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on your interaction with company systems, websites, applications, etc.	YES
G. Geolocation data.	Physical location or movements. Address only.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Sensitive Personal Information	Social Security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.	YES
L. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

*More specifically, the business purposes include:

1. Performing services for you:

To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
To assist you in completing a transaction or order;
To allow tracking of shipments;
To prepare and process invoices;
To respond to queries or requests and to provide services and support;
To provide aftersales customer relationship management;
To create and manage our customer accounts;
To notify you about changes to our services and products;
To administer any promotion, contest, survey, or competition;
To provide you information regarding our products and services,
To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.

2. Advertising customization:

For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.

3. Auditing relating to transactions, internal research and development:

To provide for internal business administration and operations, including troubleshooting, Site customization, enhancement or development, testing, research, administration and operation of our Sites and data analytics;
To create products or services that may meet your needs;
To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.

4. Security detection, protection and enforcement; functionality debugging, error repair:

As part of our efforts to keep our Sites safe and secure;
To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Sites, for example, by requesting verification information in order to reset your account password (if applicable);
To ensure the physical security of our premises through the monitoring of surveillance images;
To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.

5. Quality control:

To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures,
To develop and improve our products and services, for example, by reviewing visits to the Sites and various subpages, demand for specific products and services and user comments.

Processing Sensitive Personal Information

We collect, process and disclose Sensitive Personal Information for the purposes disclosed at the time we collect this information and for the purposes permitted by the CCPA. We only process Sensitive Personal Information for permitted purposes. The following are permitted purposes under the CCPA:

To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
To ensure the physical safety of natural persons.
For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
To perform services on behalf of our business.
To verify or maintain the quality or safety of products or services that we own or control, and to improve, upgrade, or enhance such products or services.
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Disclosing Personal Information

From time to time we disclose your information as described below. This includes disclosing information to our service providers such as professional advisers, lawyers, bankers, staffing partners, auditors and accountants, and, when required by law, to regulators or law enforcement.

A. Disclosure of Personal Information for a Business Purpose.

We may disclose your personal information to service providers and others for a business purpose. The business purposes are listed above. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we may have disclosed the following categories of personal information to service providers (such as payment processors, mail houses, marketing partners, employee benefits partners; professional advisors);affiliated companies; or government regulators or law enforcement: Identifiers, Protected personal information, Protected anti-discrimination classification information, Commercial Information, Electronic network activity information, Geolocation, Professional or employment-related information, Sensitive personal information.

B. Disclosing Personal Information in Sale Arrangements

We do not sell personal information for monetary or any other valuable consideration.

C. Sharing Personal Information for Cross-Context Behavioral Marketing

Sharing your personal information means making it available to a third party so that they can use it to display targeted or cross-context behavioral advertisement to you. Cross-context behavioral or targeted advertising means that we display an advertisement to you that is selected based on personal information about you that we obtained or inferred over time from your activities across other companies’ websites, applications or online services that we use to predict your preferences or interests. Targeted advertising does not include using your interactions with us or information that you provide to us to select advertisements to show you.

We do not share personal information for cross-context behavioral marketing purposes.

Making CCPA Requests

Access, Correction and Deletion. To exercise the access, correction, and deletion rights California residents may contact us by calling us toll free at 800-530-8350 or by emailing us at contact@consortium.net. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. Any disclosures we provide will only cover the 12-month period preceding receipt of your request, but you may request that expand the 12-month period to cover information collected since January 1, 2022, and we will honor that expanded request unless doing so would involve a disproportionate effort. You may make these requests up to twice in a 12 month period. We will acknowledge receipt of your request within 10 business days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
Opt-Out Rights. We do not sell or share personal information as defined above and do not process or disclose sensitive personal information except for purposes permitted by the CCPA.
Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorize the person to make the request on your behalf, (4) you verify your own identity directly with us and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

Retention of Personal Information

We will store personal information in a form which permits us to identify consumers, for as long as necessary for the purpose for which the personal information is processed. We may retain and use such personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information consumers provide in connection with requests made under the CPCA for a period of five years.

We reserve the right to amend this Notice at our discretion at any time. When we make changes to this Notice, we will post the updated notice on our website and update the Notice’s effective date.

California residents have the right to request to opt out of Consortium Networks “selling” or “sharing” (as defined under the California Consumer Protection Act (CCPA)) their Personal Information. Under the CCPA, a “sale” includes disclosing or making available Personal Information to a third party (other than a service provider or contractor) in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Information to a third party for cross-context behavioral advertising. You may opt out of the “sale” and/or “sharing” of Personal Information through the use of an opt-out preference signal or by completing and submitting the webform below.

Privacy Policy

This privacy notice discloses the privacy practices for Consortium Networks

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