CG Consulting, Inc. U.S. Privacy Policy

Your privacy is important to CG Consulting, Inc. (“CGCI”) so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal information. In addition to this Privacy Policy, we provide data and privacy information imbedded in our products for certain features that ask to use your personal information. You can review this information before enabling these features, in Settings related to those features or online at mycgci.com/legal/privacy.

Please take a moment to familiarize yourself with our privacy practices and contact us if you have any questions.

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person. You may be asked to provide your personal information anytime you are in contact with CGCI or an CGCI affiliated company. CGCI and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information CGCI may collect and how we may use it:

What personal information we collect

  • When you create an CGCI ID, apply for commercial credit, purchase a product, download a software update, contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information and credit card information.
  • When you share your content with family and friends using CGCI products, send gift certificates and products, or invite others to participate in CGCI services or forums, CGCI may collect the information you provide about those people such as name, mailing address, email address, and phone number. CGCI will use such information to fulfill your requests, provide the relevant product or service, or for anti-fraud purposes.
  • In certain jurisdictions, we may ask for a government issued ID in limited circumstances including when extending commercial credit, managing reservations, or as required by law.

How we use your personal information

  • We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which CGCI is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by CGCI or a third party to whom it may be necessary to disclose information.
  • The personal information we collect allows us to keep you posted on CGCI latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by updating your preferences.
  • We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.
  • We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of CGCI ID account holders.
  • From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with CGCI, you may not opt out of receiving these communications.
  • We may also use personal information for internal purposes such as auditing, data analysis, and research to improve CGCI products, services, and customer communications.
  • If you enter into a promotion we may use the information you provide to administer those programs.

Source of your personal information where they are not collected from you.

We may have received your personal information from other persons if that person has shared their content with you using CGCI products, sent gift certificates and products, or invited you to participate in CGCI services or forums. We may also validate the information provided by you when creating an CGCI ID with a third party for security and fraud prevention purposes.

For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

  • We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an CGCI product is used so that we can better understand customer behavior and improve our products, services, and advertising.
  • We may collect information regarding customer activities on our website, cloud services, and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.
  • We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.
  • With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Cookies and Other Technologies

CGCI websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Ads that are delivered by CGCI advertising platform may appear in CGCI News. If you do not wish to receive ads targeted to your interests from CGCI advertising platform, you can choose to enable Limit Ad Tracking, which will opt your CGCI ID out of receiving such ads regardless of what device you are using. If you enable Limit Ad Tracking on your mobile device, third-party apps cannot use the Advertising Identifier, a non-personal device identifier, to serve you targeted ads. You may still see ads in the CGCI News based on context like your search query or the channel you are reading. In third-party apps, you may see ads based on other information.

CGCI and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with CGCI more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the CGCI Online Store. Knowing your country and language − and if you are an educator, your school − helps us provide a customized and more useful shopping experience. Knowing someone using your computer or device has shopped for a certain product or used a particular service helps us make our advertising and email communications more relevant to your interests. And knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize your dashboard and provide you with better customer service.

If you want to disable cookies and you’re using the Safari or Internet Explorer web browser, go to Safari or Internet Explorer preferences and then to the privacy pane to manage your preferences. On your CGCI mobile device, go to Settings, then Safari or Internet Explorer, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of the CGCI website will not be available once cookies are disabled.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. CGCI may use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the CGCI website. When Clients click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.

Pixel tags enable us to send email messages in a format client can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

Disclosure to Third Parties

At times CGCI may make certain personal information available to strategic partners that work with CGCI to provide products and services, or that help CGCI market to clients. For example, if you are approved for a service, your account will be governed by CGCI privacy policies. Personal information will only be shared by CGCI to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.

Service Providers

CGCI shares personal information with companies who provide services such as information processing, extending credit, fulfilling client orders, delivering products to you, managing and enhancing client data, providing customer service, assessing your interest in our products and services, and conducting client research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever CGCI operates.

Others

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for CGCI to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Protection of Personal Information

CGCI takes the security of your personal information very seriously. CGCI online services such as the CGCI Online Store protects your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by CGCI, we use computer systems with limited access housed in facilities using physical security measures.

When you use some CGCI products, services, or applications or post on an CGCI forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

The existence of Automated Decision-Making, Including Profiling

CGCI does not take any decisions involving the use of algorithms or profiling that significantly affects you.

Integrity and Retention of Personal Information

CGCI makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods we carefully examine our need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

Access to Personal Information

You can help ensure that your contact information and preferences are accurate, complete, and up to date by signing in to your CGCI ID account page. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if CGCI is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Online tools for the exercise of access, correction, or deletion requests are available on a regional basis by signing in to privacy.mycgci.com. Where the online tool is not currently available for access requests in your region, a request may be made directly to mycgci.com/legal/contact.

Children

We understand the importance of taking extra precautions to protect the privacy and safety of children using CGCI products and services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own CGCI IDs, unless their parent provided verifiable consent.

If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible.

If at any time a parent needs to access, correct, or delete data associated with their child’s CGCI ID, they may contact us through one of the options provided at the bottom of this page.

 

Location-Based Services

To provide location-based services on CGCI products, CGCI and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your CGCI computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by CGCI and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.

 

Third‑Party Sites and Services

CGCI websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties − for example, a third‑party CGCI app.

Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

If you purchase a subscription in a third-party app or within News, we create a Subscriber ID that is unique to you and the developer or publisher which we use to provide reports to the developer or publisher that include information about the subscription you purchased, and your country of residence. If you cancel all of your subscriptions with a particular developer or publisher, the Subscriber ID will reset after 180 days if you do not resubscribe. This information is provided to developers so that they can understand the performance of their subscriptions.

Our Companywide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to CGCI employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have any questions or concerns about CGCI Privacy Policy or data processing, you would like to contact our Data Protection Officer, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us. You can always contact us by phone at the relevant CGCI Support number for your region.

When a privacy question or question about personal information received in response to an access/download request is received we have a dedicated team which triages the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

CGCI may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.

CG Consulting, Inc.
300 Spectrum Center Drive, Suite 400
Irvine, CA 92618

The CG Consulting, Inc. U.S. Privacy Policy was updated on December 30, 2018