Privacy Policy

This website privacy policy (“Privacy Policy”) describes the practices of CCI Systems, Inc. (“we”, “us”, “our” or “CCI”) regarding Personal Information collected via its website at www.ccisystems.com (the “Website”). This Privacy Policy applies only to Personal Information that we gather or collect via the Website. It does not apply to any information collected offline or otherwise outside of the Website.

If you are a California resident, please also see the below Appendix A “Privacy Information for California Residents” for supplemental California-specific privacy information.

To view our Privacy Policy regarding Meeting Recordings & Transcription, please visit: https://www.ccisystems.com/privacy-policy-meetings-recordings/ ‎

1. What Information Does the Website Collect?

When you visit our Website, we may collect information that can be used to identify you (“Personal Information”), including information related to your activities on the Website that we automatically collect as you interact with the Website (“Website Usage Information”).

(a) Personal Information You Voluntarily Provide. We collect Personal Information when you voluntarily fill out a form on the Website, register, subscribe to a newsletter or blog, send us a message, or if you use another feature on the Website. We will collect whatever Personal Information you voluntarily provide (e.g., name, phone number, postal address, and e mail address. If you fill out an online form, we will collect whatever information you enter into the form and whatever data, files or materials you upload. Likewise, if you send us a message via the website (e.g., by entering it on a “Contact Us” page), you will be sending us your name, e-mail address, and any other information, including Personal Information, you choose to include in that communication. Please note that information submitted to the Website via a “Contact Us” form or similar function may not receive a response. You are under no obligation to provide Personal Information, but if you elect not to provide it, you may be unable to use certain features of the Website or to communicate with us via the Website.

(b) Information We Automatically Collect When You Visit And Use The Website. When you visit the Website, we and our service providers may use a variety of technologies that automatically or passively collect or store certain Website Usage Information related to your activities on the Website. Website Usage Information may include your IP address or other unique identifier; your device functionality (e.g., browser, operating system, hardware, mobile network information); the URL that referred you to our Website; the areas within the Website that you visit and your activities there; your device location and characteristics and certain other device data, including the time of day and other information. We and our service providers may use a variety of technologies to collect or store Website Usage Information. These technologies may set, change, alter or modify settings or configurations on your device. These technologies may include, without limitation, cookies (a small data file placed on your computer when you visit the Website), web beacons (small graphic images or other web programming code that may be included in our web pages and e mail messages), embedded scripts (code that is designed to collect information about your interactions with the Website, such as which links you click on), ETags, or similar and technologies. Third party service providers may use such technologies with our Website and may collect information about you, including Personal Information, without notice to you.

For example, our Website includes cookies used by HubSpot, LinkedIn, and Google Analytics Advertising Features. You may disable the use of cookies by the Website, but this may limit the functionality available to you. For more information on how Google Analytics collects and processes data, please see http://www.google.com/intl/en/policies/technologies/ads/.

(c) Recruitment/EEOC/Affirmative Action Reporting. We may collect information about your education, employment history, demographics or other information as part of the recruitment process, some of which may be sensitive data. When you provide us with Personal Information or other information as part of an online employment application, we may use that information to allow us to make an informed decision about whether to proceed with your application and you expressly consent to our use of this information for the recruitment process. In addition, certain employment application self-identifying information (e.g., race and gender) may be disclosed to the government and other third parties.

(d) Children. The Website does not offer products or services to children and we do not knowingly collect any Personal Information from children younger than the age of sixteen (16). We will delete any Personal Information collected that we later determine to be from a person younger than the age of sixteen (16).

2. How do we use the Information Collected?

We may use your Personal Information for the following purposes: (1) respond to your inquiries and personalize your experience on the Website (your information helps us to better respond to your individual needs); (2) improve our Website (we continually strive to improve our Website offerings based on the information and feedback we receive from you) or our products and services; (3) provide you with information about products, services, and special offers and other information you request; (4) solicit information from you, manage your account and process payment transactions; (5) for internal business purposes, including to comply with our legal obligations; (6) for recruitment purposes and processing of employment applications, such as when the information is provided via an online employment application; (7) administer a contest, promotion, survey or other Website feature; or (8) to provide you with our products or services. In addition, Website Usage Information we collect may be used for a number of purposes, such as system administration, to help us understand the demographics of visitors to the Website, to enhance the performance and usefulness of the Website, and to audit use of the Website.

3. Sharing of Personal Information With Third Parties.

We may disclose Personal Information with third parties under various circumstances. These include, for example:

(a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on the Website to receive certain information or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. In these instances, your Personal Information and other information may be disclosed to third parties and all the information you disclose will be subject to the privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their tracking technologies, content, tools, apps, or ads on the Website or link to them from our posting or content sharing tools. We are not responsible for the privacy policies and practices of such third parties and therefore you should review their privacy policies prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services on Our Behalf. We may disclose Personal Information to third parties who perform services on our behalf. This includes, without limitation, third parties that: host the Website; operate certain functions or features of the Website; archive data; send communications; analyze data; and provide other services or functions on our behalf, including business analytics, customer service, marketing, distribution of surveys or contests, employment or hiring-related activities, data security functions, and fraud prevention.

(c) Affiliates, Business Transfers and Corporate Changes. We reserve the right to disclose Personal Information to our affiliates and in connection with a corporate divestiture, merger, consolidation, or restructuring, the sale of substantially all of our ownership interests and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process or in the event of bankruptcy, insolvency or dissolution.

(d) Administrative and Legal Reasons. We may also disclose and transfer Personal Information to third parties: (i) in the event we are required to do so to satisfy an applicable law or regulation, to respond to a court order, subpoena, discovery request, or other legal process, or if in our good faith opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an audit, investigation or other inquiry; (iii) to verify or enforce compliance with other agreements or policies governing the Website, or applicable laws, rules, and regulations; or (iv) whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of our company, customers or the Website, its users or other third parties; and in connection with our Terms of Use and other agreements. We also reserve the right to investigate, prevent, or take action regarding illegal or suspected illegal activities and to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.

(e) Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests and promotions (any, a “Promotion”) through the Website that may require registration. By participating in a Promotion, you are agreeing to official rules that govern it, which may contain specific requirements of you, such as, allowing the Promotion sponsor to use your name, voice and likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of the Promotion, including in connection with winner selection, prize fulfillment and as required by law or permitted by the official rules, such as on a winners list.

(f) Disclosing of Non-Personal Information. We may also disclose non-personally identifiable information, aggregated user statistics, and anonymous information derived from Personal Information (e.g., de identified user information), with third parties for any purpose.

In addition, we may disclose information we have collected about you, including Personal Information, as disclosed at the time you provide the information or as otherwise described in this Privacy Policy.

4. Your Choices.

You have the ability to accept or decline cookies. However, if you choose to decline cookies, you may not be able to fully experience the features of the Website or services you visit. Information on deleting or controlling cookies can be found at www.aboutcookies.org.

You can opt out of Google Analytics by:

• Changing your settings at Google’s Ad Settings at: http://www.google.com/settings/ads
• Installing an opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/
• Adjusting the settings on your web browser: See http://www.google.com/intl/en/policies/technologies/managing

Our Website does not respond to “Do Not Track” requests.

You may opt out of receiving future marketing communications from us at any time. You can opt out by using the unsubscribe process in our communications or by contacting us using the below listed methods. We will use commercially reasonable efforts to process such request in a timely manner. Depending on where you live, you may have other rights related to your Personal Information. If you have a question regarding such rights, please contact us at the below-provided information.

5. User Generated Content.

The Website may permit you to submit ideas, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on message boards and forms. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format currently existing or hereafter developed and may or may not attribute it to you. Others may have access to this User Content and may have the ability to disclose it with third parties. Please think carefully before deciding what information you provide, including Personal Information, as User Content. Please note that we do not control who will have access to the information that you choose to submit and we cannot ensure that parties who have access to it will respect your privacy or keep it secure. We are not responsible for the accuracy, use or misuse of any User Content that is received from third parties through the Website.

6. Information You Provide About a Third Party.

You may send someone else a communication from the Website, such as sending an invitation or link to a friend. If so, the information you provide is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly state otherwise. Please be aware that when you use any send- to-a-friend functionality on our Website, your e-mail address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).

7. Third Party Content and Links on the Website.

The Website may contain content that is supplied by third parties and those third parties may collect Usage Information when pages from the Websites are served to you. In addition, when you are on the Website you may be directed to other sites operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices used by any of these third parties or their sites and they may be tracking you across multiple sites and sharing the results with us and/or others. We encourage you to note when you leave our Website and to review the third party privacy policies of all third party locations and exercise caution in connection with them.

8. Security.

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed to be completely secure. Please consider this prior to submitting Personal Information to us via the Website.

9. Changes to the Privacy Policy.

We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy. We encourage you to review it regularly. Your continued use of this Website after we make changes to this Privacy Policy is deemed to be your acceptance of any changes regardless of whether you receive an email.

10. Contact Us; Questions.

If you have any questions about this Website you may contact us via e-mail at info@ccisystems.com , via phone at +1 (800) 338-9299, or via mail at:

Appendix A

Privacy Information for California Residents

This Appendix applies solely to individuals who reside in the State of California (“consumers” or “you”) and describes the Personal Information collection practices of CCI both through the Website and offline. This Appendix complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Appendix. This Appendix does not apply to Personal Information outside the scope of the CCPA.

1. CCI as a Service Provider

When we act as a service provider for our customers, we collect Personal Information on behalf of our customers subject to our contractual obligations. When we act as a service provider, we follow the instructions of our customer on how to process Personal Information on our customer’s behalf. The provisions of this Appendix do not apply to the Personal Information that we process on behalf of our business customers.

2. What Personal Information We Collect and How We Disclose it

The chart below lists the categories of Personal Information that we may collect and have collected in the past 12 months and how we use such information.

Categories of Personal Information	Categories of Services Providers and Third Parties with whom Personal Information is Disclosed
Identifiers. This may include a real name, alias, address, email address, phone number, online identifier, IP address, account username, job title, employer name, or other similar identifiers.	Entities that we are required to disclose with pursuant to law or for legal proceedings; service providers; our affiliates; data analytics providers; prospective purchasers of our business; outside auditors and lawyers; social media networks; and any other third party you approve of.
Internet and network information. This may include information on your interaction with the Website or advertisement, such as browsing history and how you use your account.	Entities that we are required to disclose with pursuant to law or for legal proceedings; service providers; our affiliates; data analytics providers; and any other third party you approve of.
Device information. This may include the operating system of your device, device identifier, the type of device you are using, or your geolocation information.	Entities that we are required to disclose with pursuant to law or for legal proceedings; service providers; data analytics providers; and any other third party you approve of.
Services Information. This may include information about what Services you order, complaints, or communications you have with us related to the Services.	Entities that we are required to disclose with pursuant to law or for legal proceedings; service providers; our affiliates; prospective purchasers of our business; and any other third party you approve of.
Payment information. This may include your banking information, information about your payment transaction, or other financial information you provide us.	Entities that we are required to disclose with pursuant to law or for legal proceedings; service providers; our affiliates; prospective purchasers of our business; outside auditors and lawyers; any other third party you approve of.
Other information you submit to us. This may include requests or communications you submit to us, including emails, ratings, or customer service call recording.	Entities that we are required to disclose with pursuant to law or for legal proceedings; service providers; our affiliates; prospective purchasers of our business; outside auditors and lawyers; and any other third party you approve of.
Research or survey information. This may include survey results, social media data, and other information about your participation in consumer research.	Entities that we are required to disclose with pursuant to law or for legal proceedings; service providers; our affiliates; and prospective purchasers of our business.
Inferences we draw about you. This may include information about your preferences, behavior, or other trends that help us identify which products you may be interested in.	Entities that we are required to disclose with pursuant to law or for legal proceedings; service providers; our affiliates; data analytics providers; and any other third party you approve of.
Applicant information. This may include information on your resume or contained in an employment application, including references, employment history, training, or educational history.	Entities that we are required to disclose with pursuant to law or for legal proceedings; service providers; our affiliates; prospective purchasers of our business; outside auditors and lawyers; and any other third party you approve of.

3. How We Use Personal Information

We may use Personal Information in the following ways:

• To provide you with information or the services and respond to your inquiries and personalize your experience on the Website;
• To improve our Website or services;
• To solicit information from you, manage your account, and process payment transactions;
• To advertise or market to you;
• For our own legal obligations;
• For recruitment purposes and processing of employment applications, such as when the information is provided via an online employment application;
• To administer a contest, promotion, survey or other Website feature;
• To provide you or your company with our products or services; or
• Or as otherwise described to you when we collect your Personal Information.

4. “Sale” and “Sharing” of Personal Information

When you interact with our Website, we may use, or authorize third-party partners and service providers to use, cookies, web beacons and similar technologies to improve your experience with us. Our sharing of your personal information in this way may constitute “selling”, “sharing”, or using for “targeted advertising” under California law. The term “sale” is broadly defined by the California Consumer Privacy Act and includes sharing personal information for monetary or other valuable consideration.

To the extent this is considered “selling”, “sharing”, or “targeted advertising”, in the preceding 12 months, we have sold or shared the following categories of personal information for the purpose of showing you ads about our services and products:

• Identifiers
• Internet or other similar network activity

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by clicking on the “Do Not Sell or Share My Personal Information” link below. You do not need to create an account with us to exercise your opt-out rights.

In addition, some browsers offer you the ability to opt out of the sharing of your personal information by turning on a Global Privacy Control. You can turn on a Global Privacy Control in your web browser or browser extension or by visiting https://globalprivacycontrol.org/. Please see the California Privacy Protection Agency’s website at https://oag.ca.gov/privacy/ccpa for more information on valid Global Privacy Controls. At this time, we endeavor to respond to browser-based opt-out signals sent through the Global Privacy Control.

5. California Residents’ Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information, described below. Below are your CCPA rights and how to exercise those rights.

• Right to Know: 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. You could request:
  
  • the categories of Personal Information we collected about you;
  • the categories of sources of the Personal Information we collected about you;
  • our business or commercial purpose for collecting that Personal Information;
  • the categories of third parties with whom we disclose that Personal Information; or
  • the specific pieces of Personal Information we collected about you.
• Right to Request Deletion: You have the right to request that we delete some or all of the Personal Information that we have collected from you and retained, subject to a number of exceptions. We are not required to delete Personal Information that is:
  
  • necessary to complete a transaction with you or for warranty or product recalls;
  • used for security purposes, to prevent fraud, to fix errors, or to comply with law;
  • reasonable for us to use for internal purposes given our relationship with you; or
  • compatible with the context in which you provided the information.

The list of exceptions above is not exhaustive, and we may also deny a deletion request as otherwise permitted by law.

• Right to Correct: You have the right to request that we correct any inaccurate Personal Information that we maintain about you.
• Right of Portability: You have the right to request a copy of your information in an accessible format.
• The Right to Opt Out of the Sale or Sharing of Your Personal Information in Certain Circumstances: The right to direct us not to sell or share Personal Information we have collected about you to third parties for targeted advertising.
• The Right to Limited Use and Disclosure of Sensitive Personal Information: You may have the right to limit the use or sharing of your sensitive Personal Information.

a. Exercising Your Rights

To exercise your rights described above, please submit a verifiable consumer request to CCI Systems by either:

• Calling CCI Systems at (906) 771-2500.
• Emailing CCI Systems at privacy@ccisystems.com.

Only you, or a person that you authorize 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. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual.

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 may not be able to fulfill your request or provide you with Personal Information if it cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. To verify your identity, we may request up to up to three pieces of Personal Information about you, and we reserve the right to take additional steps as necessary to verify your identity if it has reason to believe a request is fraudulent.

b. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), it will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the date it receives your verifiable consumer request. The response it provides 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, it will tell you why it made that decision and provide you with a cost estimate before completing your request.

c. Non-Discrimination

You have the right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.

6. Retention

Our retention periods for Personal Information are based on business needs and legal requirements. We will retain your Personal Information for as long as necessary to provide our products and services to you and otherwise as long as is necessary for the processing purpose(s) for which it was collected and any other permitted or legally required purpose.

7. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding its disclosure of Personal Information to third parties for its direct marketing purposes. To make such a request, please contact us through the information provided above. We do not respond to “do not track” requests. All traffic is treated as equal and processed the same, except as required by applicable law. If you desire to have your browsing be private, we suggest that you use your web browser’s private or incognito function, or a similar option.