A. This Policy
Summary – This Policy
This Policy explains how we may Process your Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates.
This Policy is issued by Consensus Cloud Solutions, LLC (a subsidiary of Consensus Cloud Solutions, Inc.) on behalf of itself, its subsidiaries and its affiliates (together, “Company”, “we”, “ us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, and other users of our services (together, “you”). Defined terms used in this Policy are explained in Section (S) below.
B. Collection of Personal Data
Summary – Collection of Personal Data
We may collect or obtain Personal Data about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make your Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, or services; or when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).
Collection of Personal Data: We may collect Personal Data about you from the following sources:
C. Creation of Personal Data
We may also create Personal Data about you, such as records of your interactions with us, and details of your purchase history for internal administration purposes and analysis.
D. Categories of Personal Data we may Process
Summary – Categories of Personal Data we may Process
We may Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Sites and Apps (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.
We may Process the following categories of Personal Data about you:
E. Lawful basis for Processing Personal Data
Summary – Lawful basis for Processing Personal Data
We may Process your Personal Data where: you have given your prior, express consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the Processing.
In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:
F. Sensitive Personal Data
Summary – Sensitive Personal Data
We do not seek to collect or otherwise Process your Sensitive Personal Data. Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
We do not seek to collect or otherwise Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
G. Purposes for which we may Process your Personal Data
Summary – Purposes for which we may Process your Personal Data
We may Process your Personal Data for the following purposes: providing services to you; operating our Sites and Apps; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; and improving our Sites, Apps, and services.
The purposes for which we may Process Personal Data, subject to applicable law, include:
H. Disclosure of Personal Data to third parties
Summary – Disclosure of Personal Data to third parties
We may disclose your Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites or our Apps.
We may disclose your Personal Data to other entities within the Company group, for legitimate business purposes (including operating our Sites and our Apps, and providing services to you), in accordance with applicable law. In addition, we may disclose your Personal Data to:
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
I. International transfer of Personal Data
Summary – International transfer of Personal Data
We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.
Because of the international nature of our business, we may need to transfer your Personal Data within the Company group, and to third parties as noted in Section (H) above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You may request a copy of our Standard Contractual Clauses using the contact details provided in Section (R) below.
J. Data security
Summary – Data security
We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us is sent securely.
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
K. Data accuracy
Summary – Data accuracy
We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
We take every reasonable step to ensure that:
L. Data minimisation
Summary – Data minimisation
We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to our Apps and Sites.
M. Data retention
Summary – Data retention
We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed.
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy.
The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.
N. Your legal rights
Summary – Your legal rights
Under applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.
Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:
Summary – Cookies and similar technologies
We may Process your Personal Data by placing or reading Cookies and similar technologies.
What is a cookie?
A cookie is a piece of data stored on your computer and tied to information about you. By using and browsing our Sites, you consent to the use by us and third parties of cookies and other technologies in accordance with this Policy.
What are the different types of cookies?
First party cookies are our own cookies set by our Site, controlled by us, and used to provide information about the usage of our Site.
How long do cookies stay on your computer?
Two types of cookies may be used on the Site, session cookies and persistent cookies.
Session cookies are temporary cookies that remain in your browser or device until you leave the site; they are deleted from your device once you leave the Service.
Persistent cookies are small files stored on your hard drive until you delete them or until they reach their expiry date. These may, for example, be used to remember your preferences when you use the Site, recognize you on your return, and enhance your experience on the Site (see more about profiles below). Use of a persistent cookie is not linked to any personally identifiable information while on the Site except if you choose to store your user names and PINs so that you do not have to enter them each time you access your accounts. Then, a persistent cookie will be stored on your computer, which is linked to your account information. If you reject the persistent cookie, you may still use the Site but you will be limited in some areas of it.
What other technologies do we use?
Can I Change My Cookie Preferences?
Browser settings allow you to choose whether or not to accept cookies or limit certain cookies. Most browsers also provide functionality that lets you review and erase cookies. If you use our Sites without changing your browser settings, we will assume that you are happy to receive all cookies on our Sites. Please be aware that if cookies are disabled, not all features of the Site may operate as intended.
Your mobile operating system may let you opt out from having your information collected or used for interest-based advertising on mobile devices. You should refer to the instructions provided by your mobile device’s manufacturer, but this functionality is usually available in the “Settings” section of your device. You can also stop us from collecting information through our applications by uninstalling our applications. For more information about these specialized cookies and other technologies, and to learn more about behavioral advertising or to opt out of this type of advertising for some companies, you can visit http://www.networkadvertising.org or http://networkadvertising.org/optout_nonppii.asp.
The Terms of Service located on our website will govern all use of our Sites and our Apps.
All use of our Sites, our Apps, or our services is subject to our Terms of Service. We recommend that you review our Terms of Service regularly, in order to review any changes we might make from time to time.
Q. Direct marketing
Summary – Direct marketing
We may Process your Personal Data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.
We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our promotional email list at any time by following the unsubscribe instructions included in every promotional email we send. We will not send you promotional emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any services you have requested or from additional lists you have signed up under.
R. Contact details
Summary – A
To submit a Data Subject Access Request, a Data Subject Erasure Request, or to exercise other rights under the GDPR, please use the following form: Consensus DSAR Form
If you wish to be taken off our contact list for direct marketing, please contact: [email protected].
If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact
The Company, or Company affiliate, has appointed a Data Protection Officer who may be contacted at [email protected].
- “ App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
- “ Adequate Jurisdiction” a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
- “ Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
- “ Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
- “ Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
- “ EEA” means the European Economic Area.
- “ Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
- “ Process”, “ Processing” or “ Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- “ Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
- “ Relevant Personal Data” means Personal Data in respect of which we are the Controller. It expressly does not include Personal Data of which we are not the Controller.
- “ Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
- “ Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
- “ Site” means any website operated, or maintained, by us or on our behalf.
T. California Consumer Privacy Act Addendum
In accordance with the California Consumer Privacy Act, if you are a consumer residing in California the following addition terms apply to you.
(1) Right to Know About Information Collected, Disclosed or Sold
If you have an account with us, we will verify the request by confirming the email address used to make the request is the same as the email address on file for the account. If you do not have an account with us, we will verify the request by sending an email to the email address used to make the request.
The categories of California consumers personal information we may collect are listed above in Section (D) (Categories of Personal Data).
With reference to section (D) above, we collect the following categories of data from our customers: personal details; demographic information; contact details; consent records; purchase details; payment details; data relating to our Sites and Apps; employer details; content and advertising data; and views and opinions of our customers. We use this data for the purposes listed above in Section (G) (ï¿½Purposes for which we may Process your Personal Dataï¿½).
With further reference to section (D) above, we collect the following categories of data from website visitors: data relating to our Sites; employer details; content and advertising data; and the views and opinions of website visitors. We use this data for the purposes listed above in Section (G) (ï¿½Purposes for which we may Process your Personal Dataï¿½).
We confirm we have not sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. We confirm we do not sell personal information of minors under 16 years of age without authorization. We may disclose the categories of Personal Information listed in Section (G) to our vendors and service providers for a business purpose.
(2) Right to Request Deletion of Personal Information
If you are a current or former customer submitting a request by web form or email, please provide sufficient information to identify your account, including your email address on file with us. You may be asked to verify your identity by responding to us with the email address on file for the account.
If you are not a current or former customer, we may ask for proof of identity sufficient to show you are the same consumer about whom we have collected personal information that you are requesting to be deleted.
(3) Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information by a business. Pursuant to California law, because we do not and will not sell your personal information, we do not offer such an opt-out at this time.
(4) Right to Non-Discrimination for the Exercise of a ConsumerÂ’s Privacy Rights
You have the right not to receive discriminatory treatment by the business for the exercise of the privacy rights conferred by the California Consumer Privacy Act.
(5) Authorized Agent
If you would like to make a request under the California Consumer Privacy Act on behalf of a California consumer who is a current or former customer, please provide an email from the email address we have on file for the customer authorizing the request.
You may also make a request under the California Consumer Privacy Act on behalf of a California consumer if you provide (1) a signed, written permission from the consumer to act on your behalf, and the consumer verifies their own identity directly with us; or (2) proof that the consumer has provided you with power of attorney pursuant to Probate Code sections 4000 to 4465.
We may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
(6) Contact for More Information
700 S. Flower St., 15th Floor, Los Angeles, CA 90017