CTS Customer Portal Privacy Policy
Communication Technology Services, LLC (“CTS”) knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. We take your privacy seriously. You can learn more about the Privacy Policy applicable to our customer portal portal.cts1.com (the “Portal” and “Portal Privacy Policy”) below. By visiting this Portal and providing any personal information, you are consenting to the practices described in this Portal Privacy Policy (this “Policy”).
What Does This Privacy Policy Cover?
This Policy covers how CTS treats personal information that CTS collects and receives via the Portal. This includes information about you that is personally identifiable, such as your name, address, email address, IP address and phone number, and information related to your interest in and use of CTS Services.
What Information Do We Collect?
We collect the following types of information.
• Information You Provide. When you use the Portal, we collect what is generally called “personally identifiable information," “personal information,” or “personal data.” All these terms refer to information that specifically relates to or identifies a particular individual. Personal information also includes information that when linked to other information identifies a specific individual. We collect a limited amount of personal information, including but not limited to, your name, phone number and email address.
• “Cookies" Information. When you go to the Portal, you are not anonymous to us. We may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Portal. Consult your device's web browser “Help" file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the Portal or one of our Services, you may not be able to utilize the features of the Portal or Service to their fullest potential.
• “Automatically Collected" Information. When you use the Portal, we may automatically record certain information from your device by using various types of technology, including “clear gifs" or APIs. This “automatically collected" information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Portal, the pages or other content you view or otherwise interact with on the Portal, and the dates and times that you visit, access, or use the Portal. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked through, or forwarded a message. This information is gathered from all users.
What Are the Legal Bases for Our Collection of Information?
We collect and process your personal data using one or more of the following legal grounds:
• Legitimate interest
• Your consent.
How Do We Use the Information We Collect?
We use the information we collect in a variety of ways in operating the Portal and our business, including the following:
• We use the information that we collect to operate, maintain, enhance and provide all features of the Portal, to provide services and information that you request, to respond to comments and questions, and otherwise to provide support to users.
• We use the information that we collect to understand and analyze the usage trends and preferences of our users, to improve the Portal, and to develop new products, services, features, and functionality.
• We may use your email address or other information we collect (i) to contact you for administrative purposes and to address claimed violations of our terms of use; or (ii) to send communications, including updates on promotions and events, relating to products and services offered by us. Generally, you have the ability to opt out of receiving any promotional communications as described below under “Your Choices.”
• We may use “cookies” information and “automatically collected” information to: (i) personalize our Portal or services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Portal; (ii) provide customized content and information; (iii) monitor and analyze the effectiveness of the Portal; and (iv) monitor aggregate Portal usage metrics such as total number of visitors and pages viewed.
Sharing or Disclosing Information
Information about our customers and potential customers is an important part of our business. We DO NOT sell customer information. We share or disclose customer information only as described below. Except as described in this Policy, we will not disclose your information that we collect on the Portal to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
• We work with third-party service providers that provide application development, hosting, maintenance, data transmission, data processing, and other services for the Portal. These third parties may have access to or process your information as part of providing those services for us. However, we limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions. In addition, they agree by contract to maintain the confidentiality of such information.
• We may make certain automatically-collected, aggregated or non-personally-identifiable information available to third parties for various purposes, including (i) to monitor network traffic or activity in order to protect you, ourselves or others from malware, fraud, unlawful uses or other illegal activity; (ii) to comply with various reporting obligations; (iii) for business or marketing purposes; or (iv) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, or functionality available through the Portal.
• In addition, we have implemented certain Google Analytics features on our Portal. Visitors may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager, and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.
• We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state or federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
• We also reserve the right to disclose your information when we believe, in good faith, that disclosure is appropriate or necessary to (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend ourselves against any third party claims or allegations; (iv) protect the security or integrity of the Portal or any facilities or equipment used to make our services available; or (v) protect our property or legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
• Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer of CTS, or to a successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. In the event CTS is acquired by or merged with another company, the terms of this Privacy Policy shall continue to apply. In this event, CTS will notify you before information about you is transferred and becomes subject to a different privacy policy.
Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information. To learn more about your choices related to how we share your information with third parties, please see the “Your Choices” section below. CTS also reserves the right to display targeted advertisements based on personal information.
Your Choices
You may access, change or delete personal information that you have provided or that we hold about you. In addition, you may request that we not disclose your personal information to third parties (other than those that are acting as our agent to perform tasks related to the Portal on our behalf, such as data processors).
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out of receiving commercial email from us, and any other promotional communications that we may send to you from time to time.
Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request, and you may receive promotional communications from us during that period. Additionally, even after you opt out of receiving commercial messages from us, you will continue to receive administrative messages from us regarding the services.
You may withdraw consent to certain data sharing or usage or exercise any of these rights above by sending your request to us by email at privacy@cts1.com or by writing to us at the address given at the end of this policy.
If you are a user of the Service in the European Union or certain other countries, you have certain additional legal rights with regard to your information, including those identified below. Some of these rights may be subject to some exceptions or limitations. We will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request).
• The right to object to profiling;
• The right to lodge a complaint with a supervisory authority; and
• Data portability rights (This means that you have the right to receive your personal data in a structured, commonly-used and machine-readable format, and that you have the right to transmit that data to another controller.)
Third-Party Services
The Portal may contain features or links to websites and services provided by third parties that are not affiliated with CTS. This Privacy Policy does not apply to the practices of such companies. When you visit the Portal or use one of the services, third parties may collect personal information about your online activities. These third parties may also collect personal information about your online activities across different Portals or applications over time. Any information you provide on third party sites or through third party services is provided directly to the operators of such services and is subject to those operators’ policies governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
Confidentiality and Security
CTS limits internal access to your personal information to employees who we reasonably believe require this information in order to do their jobs or to provide products and services to you. We use industry-standard measures to help protect the integrity and security of personal information that we collect and maintain. We cannot, however, ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on the Portal if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
International Users and Data Transfers
The Portal is hosted in the United States and is intended for visitors located within the United States as well as users located outside of the United States. If you choose to use the Portal from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Portal. By providing any information, including personal information, on or to the Portal, you consent to such transfer, storage, and processing. Businesses cannot deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights under the CCPA.
Conclusion
CTS may update this policy at any time. We will notify you by placing a notice in a prominent place on our Portal and by sending a notice to the primary email address you specified for your CTS account. If you have further questions or suggestions regarding this Privacy Policy, you can contact us at privacy@cts1.com.
Notice for California Users
Under Cal. Civ. Code § 1798.80, a user residing in the State of California has the right to request from us a list of all third parties to which we have disclosed personal information during the preceding year for direct marketing purposes. We do not disclose such information for direct marketing purposes, and so no such list exists. We do not obey Do Not Track signals from a user’s Internet browser. We make no representations concerning third parties that do not collect personal information directly through the Website. These disclosures are made under Cal. Bus. & Prof. Code § 22575.