The Website is not intended for use by individuals under the age of 18 and we do not knowingly collect personally identifiable information (relating to an identified or identifiable individual) (“PII”) from anyone under the age of 18.
In the European Union (“EU”), the processing of personal identifiable data is governed by the General Data Protection Regulation 2016/679 (“GDPR”). Under the GDPR, personal identifiable data is defined as: “Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, 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 natural person.” CNI complies with its obligations under GDPR by keeping PII up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting PII from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect PII. The legal bases for CNI’s processing activities include processing such information as necessary to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, and pursuant to your consent.
“CCPA” means the California Consumer Privacy Act. If you are a resident of California, under the CCPA you have the following rights:
The right to notice. You must be properly notified which categories of personal data are being collected and the purposes for which the personal data is being used.
The right to access / the right to request. The CCPA permits you to request and obtain from the CNI information regarding the disclosure of your personal data that has been collected in the past 12 months by CNI or its subsidiaries to a third-party for the third party’s direct marketing purposes.
The right to say no to the sale of personal data. The CCPA also gives you the right to ask CNI not to sell your personal data to third parties. CNI has determined that it will not sell personal data to third parties at this time. If CNI were to determine that it might sell personal data collected in the future to third parties, CNI would first establish a “Do Not Sell My Personal Information” section or web page for you to request that it not do so in accordance with the CCPA.
The right to know about your personal data. You have the right to request and obtain from CNI information regarding the disclosure of the following:
- The categories of personal data collected
- The sources from which the personal data was collected
- The business or commercial purpose for collecting or selling the personal data
- Categories of third parties with whom we share personal data
- The specific pieces of personal data we collected about you
The right to delete personal data. You also have the right to request the deletion of your personal data that has been collected in the past 12 months.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
- Exercising Your CCPA Data Protection Rights
Authorized Agent. You have the right to designate an authorized agent to make a request under the CCPA on your behalf. Please note that you must provide your authorized agent written permission to so act on your behalf, and your authorized agent must provide us with a copy of this document.
If you are a California resident, in order to exercise any of your rights under the CCPA, you can email us at email@example.com. Please include the words “CCPA Data Protection” in the subject matter box of your email. The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
- The Information Collected
Our servers also may automatically collect information about you, your online behavior and your computer, mobile or other device. The information collected may include, without limitation, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your computer, mobile or other device, as well as date/time stamp, IP address, pages visited, time of visits, content viewed, ads (if any) viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data.
“Do Not Track” Technology – Some newer web browsers have a “Do Not Track” preference that transmits a “Do Not Track” header to the websites you visit with information indicating that you do not want your activity to be tracked. We currently do not respond to browser “Do Not Track” signals.
- Use of the Information
We use the PII you provide about yourself to administer your account, fulfill your requests for and provide you with access to our services, programs, and products, to respond to your inquiries about our offerings, and to offer you other services, programs, or products that we believe may be of interest to you. We also may use this information to communicate with you when we make changes to our subscriber agreements, to fulfill a request by you for an online newsletter, or to contact you about your account with us. In addition to the foregoing, we use the information you provide in connection with our social, community, and public discussion areas or as part of a User Submission to provide an interactive experience on the Website. For example, we may use this information to write e-mails, to publish submissions, to offer suggestions to and share stories with our readers or to offer you services, programs, or products.
We will not sell, transfer or otherwise disclose your PII to third parties, except as follows: (i) we may use third parties to perform specific functions on our behalf and we may disclose such information to help those parties perform their services; (ii) we may disclose such information in response to a legal process, order or investigation (for example, a subpoena or court order); (iii) we may disclose PII where disclosure is necessary to protect our legal rights or to protect us or others (for example, in order to reduce the risk of fraud or illegal activities); (iv) we may share or choose to sell such information with companies related to ours, and our affiliates, subsidiaries, business partners and advertisers for the purpose of marketing products, programs and services to you or for any other purpose related to our or their businesses; and (v) we may acquire, merge with or be acquired by another company or we might sell some or all of our assets, and, in such a case, we may sell and/or disclose your PII to another company.
We may use the information we collect about you, your online behavior and your computer, mobile or other device to improve the design and content of the Website and to enable us to personalize your Internet experience. We may also use this information in the aggregate to analyze site usage, as well as to offer you services, programs, or products. In addition, we reserve the right to use this information, which may at times be able to identify you, for any lawful business purpose, including without limitation to help diagnose problems with our servers, to gather broad demographic information, analyze trends, track users’ movements around the Website, and to otherwise administer the Website. In addition to all of the foregoing, we reserve the right to use, transfer, sell, and share aggregated, anonymous data about our users as a group for any lawful business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, and customers. CNI may combine information we receive online with outside records to enhance our ability to offer information or market to you those services or products that may be of interest to you.
- Cookies and Other Technologies
In addition to Local Device Storage, we may use web beacons, also known as clear gifs, pixel tags, or web bugs (collectively, together with Local Device Storage, the “Tracking Technologies”). We may use Tracking Technologies for many of the purposes described above, in addition to allowing our service providers to track visitor traffic and actions on our Website. Third party service providers, including Facebook, may use Tracking Technologies to collect or receive information from our Website and elsewhere on the internet and use that information to provide measurement services and targeted advertisements.
We take precautions and have implemented certain technical measures intended to protect against unauthorized access to, loss of, disclosure of, and unlawful interception of PII submitted via the Website. We also limit internal access to PII to a select list of our personnel on a “need-to-know” basis. However, because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the information you send to us or the security of our servers, networks or databases. Your communications containing PII may be unlawfully intercepted or accessed by third parties and/or the Website may be subject to network attacks or malfunctions. Accordingly, we cannot and do not guarantee that your PII or any other information is completely secure and safe from any risk, and you provide information to us at your sole risk. By using the Website you agree that we are not responsible for any inadvertent loss of such information or the consequences thereof.
- Links to/from Other Sites
The Website contains links to other web sites that are operated by third parties. With prior permission, other sites may also reference or link to the Website. To obtain permission, send an e-mail to firstname.lastname@example.org. The services or products described or advertised on the Website are generally sold by other parties on other sites. CNI is not responsible for the privacy practices or the content of those other sites. CNI makes no representations concerning any effort to review the content of sites to which it may be linked and has no control over information submitted to other sites. Visitors should consult the other sites’ privacy notices prior to submitting any information to those sites, as we have no control over information that is submitted to, or collected by, these third parties.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
VII. Your Access to Your PII
If you would like to know the types of information that CNI collects from visitors to the Website, please contact us. If you would like to know whether CNI has collected PII about you, please send us the activities that you participated in on our Website which requested PII; after reviewing the relevant databases, we will confirm whether we have collected such information about you. You may review PII about you in our records at any time provided you first give us proof of your identity via postal mail or by email, such as a copy of a valid driver’s license with your name and address. You will have the ability to update your personal information in your user profile page, and, if you request, we will change any inaccuracies in the PII we have that pertains to you, and/or end any direct communications with you, or even delete your PII altogether. Even after such modification or deletion, however, there may be residual information that will remain within our databases that may or may not contain PII. This residual information will not be given to any third party or used for any commercial purpose. The Website shall comply with any state privacy laws with respect to collection of personal information, including, but not limited to, the California Shine the Light Law.
Last Updated: September 3, 2020