COMMITMENT TO YOUR PRIVACY
The Effective Date of this Privacy Policy is September 2024. This version of the Privacy Policy replaces and supersedes any prior privacy policies applicable to the Site, as defined below.
Summary and Contact Information
We at CSafe (the “Company,” “we,” “our,” or “us”) recognize the importance of protecting the privacy of personally identifiable information (“Personal Information”). This Privacy Policy (“Policy”) applies to Personal Information collected through our website, located at csafeglobal.com (the “Site”) or from your use of our products, including without limitation any software applications (collectively, the Site and our other products are the “Services”).
This Policy applies to our information collection practices outside of the European Union (“EU”). A separate privacy policy, available at https://csafeglobal.com/about-csafe/website-policies/#eu-privacy-policy applies to our information collection practices within the EU.
If you have any questions about this Policy or wish to contact us, we can be reached at:
Attn: Data Privacy Officer
E-mail: [email protected]
For America’s: CSafe
675 Gateway Blvd.
Monroe, OH 45050
Tel: +1 513 360 7189 (EST business hours)
For EPAC: Softbox Systems PTE. LTD
2 Bukit Batok Street 23 #05-04
Bukit Batok Connection
Singapore (659554)
Tel: + 65 6316 9584 (Singapore business hours)
COLLECTION AND USE OF INFORMATION
We are the sole owner of information collected on the Site. The information we collect depends on what you do when you visit the Site or utilize the Services. By accessing the Site and/or using the Services, you are consenting to our use of your Personal Information in accordance with this Policy. Further, your access to and use of the Services is subject to our Terms and Conditions, located at https://csafeglobal.com/about-csafe/website-policies/#terms-conditions.
Information We Collect About You
Personal Information: We use the term Personal Information to mean any information that could be used to identify you, including your name, address, email address, and/or any combination of information that could be used to identify you.
When you interact with our Site or otherwise use our Services, we collect Personal Information that you choose to share with us. For example, you may share Personal Information with us when you complete forms on the Site, navigate through the Site, and utilize our other Services.
In the past twelve (12) months, we have collected, used, stored, and/or disclosed the following types of Personal Information, where relevant:
Category |
Type(s) of Information |
Identifiers |
First Name, Last Name, Address, Email, Phone Number, IP Address |
Financial Information |
Credit/Debit Card Number, Expiration Date, Security Code, Billing Account Number, Bank Account Information, and Other Financial Information |
Categories of Personal Information listed in the CA Consumer Customer Records law |
First Name, Last Name, Address, Phone Number, Credit/Debit Card Number, Tax Identification Number, Passport Number, Driver’s License, State Identification Card Number, Education, Employment, Employment History
Information within this category may overlap with other categories. |
Characteristics of Protected Classifications Under CA or US Law |
Age (40 years or older), race, national origin, citizenship, sex |
Professional or Employment-Related Information. |
Past job history |
Internet or Other Similar Network Activities |
Browsing History, Search History, Interactions with the Site |
Inferences Drawn From Other Personal Information
|
Profile reflecting a person’s preferences, characteristics, and behavior
|
Geolocation Data |
Geolocation, beacon-based location, GPS location
You may disable our use of certain identifiers and activities through your device or browser settings. |
Sensitive Information: If you apply for employment with us, we may collect Personal Information that, under certain circumstances, could be considered Sensitive Personal Information, as that term is defined within the CCPA (“Sensitive Personal Information”). However, we do not collect or use this Sensitive Personal Information to infer characteristics about you, but rather solely for direct purposes related to the hiring process, as permitted by law. Otherwise, we do not collect Sensitive Personal Information from you.
Deidentified Information: We may collect deidentified information from you that may not by itself reasonably identify you as the source when you navigate the Site or use our Services (“Deidentified Information”). Deidentified Information may include: (i) device type, (ii) device operating system, (iii) internet browser type, (iv) internet service provider, (v) referring/exit pages, (vi) date/time stamp, and (vii) clickstream information. We will take reasonable measures to ensure that Deidentified Information we collect is not personally identifiable and may not later be easily used to identify you.
Children’s Information: Our Services and the Site are not directed to children under the age of 18. We will use commercially reasonable efforts to delete any Personal Information or other information later determined to be provided by a child under the age of 18. If you become aware that a minor has provided Personal Information through our Site, please email us at [email protected].
How We Collect Your Information
The information we collect depends on what you do when you visit the Site or utilize the Services. We collect Personal Information and Deidentified Information in various ways, including:
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When you provide it to us. You may provide Personal Information to us when you enter or upload information into the Site or otherwise through our Services, create an account, apply for a job, or communicate with us via telephone, email, or otherwise.
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Through technical means. When you visit the Site or use our Services, we may collect your Personal Information using cookies and other similar technology. A cookie is a small amount of data, often including a unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive. For information on how we utilize cookies, please see our Cookie Policy located at https://csafeglobal.com/about-csafe/website-policies/#cookie-policy.
In particular, the Site uses Google Analytics, an analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site. The information generated by the cookie about your use of the Site will be transmitted to and stored by Google. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators and providing other services relating to Site activity and internet usage, including tracking which pages of our Site you visit so we can optimize your experience with our Site. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. We have implemented the IP anonymization feature in Google Analytics which anonymizes your IP address to protect individual privacy. You can opt-out from the collection of this information by Google by downloading and installing a browser plug-in at https://tools.google.com/dlpage/gaoptout. For more information on Google Analytics privacy practices, read here and, for information on Google Analytics cookies expiration, read here.
When you use the Site or Services, we may also receive Personal Information your device communicates to us, such as information about your location, and other technical information about your device and the software it uses.
We may also use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.
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Through social media. We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture and gender) to deliver the content or as part of the operation of the Site, plug-in or application.
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When your organization or a third party provides it to us. Your organization may provide us with your Personal Information so that we can activate and manage your access and use of the Site or our Services. We may also receive your Personal Information from carefully vetted third parties who provide services on our behalf (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies).
How We Use Your Personal Information
We use your Personal Information for the following business purposes to help enhance your experience:
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to perform our obligations arising under our contract with you;
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to send you promotional materials;
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to provide you with information you request;
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to process your application for employment;
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to notify you about changes to the Services we offer;
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to ensure the content provided on the Site or through our Services is presented in the most effective manner for you and for your device;
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to administer the Site and Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
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as part of our efforts to keep the Site and Services safe and secure;
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to measure or understand the effectiveness of advertising we serve to you and others;
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to deliver relevant advertising to you (unless you choose to opt out of such communications as set forth below);
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to distinguish you from other users of the Site;
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for any other purpose disclosed by us when you provide the information; and
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with your consent.
We may also anonymize your Personal Information so that it cannot be associated with you or any individual (“Anonymized Data”). You acknowledge and agree that we own all right and title to Anonymized Data, and that we may make use of the Anonymized Data in any way that we see fit.
How Long We Retain Your Personal Information
We keep your Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so in connection with your account, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is longer.
SHARING PERSONAL INFORMATION
We may disclose your Personal Information to others for a business purpose as described below. Otherwise, we do not sell, rent, lease, or “share” Personal Information, and will not disclose Personal Information to third parties without your permission. The CCPA defines “sharing” as the disclosure of Personal Information for cross-context behavioral advertising.
Affiliates. We reserve the right to transfer Personal Information to our affiliates, including companies within the CSafe Global group.
Service Providers. We may transfer Personal Information to our service providers that assist us in providing user support, evaluating job candidates, and promoting our Services, as well as service providers that provide other services to us relating to our Services and/or the Site. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers, contractors, and third parties, as required, to ensure they can only use your Personal Information to provide services to us and to you.
In Connection with a Corporate Transaction. We may provide your Personal Information to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of the Company or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy. We may also share your Personal Information in the diligence process or to otherwise facilitate any such transaction, and with individuals assisting in the transaction or in connection with a bankruptcy.
For Safety and Security. We may reveal your Personal Information to law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity or in order to protect the safety and security of our users or any third party.
For Legal and Compliance Reasons. We may disclose your Personal Information to the extent we reasonably believe we are required or permitted to do so by law or to comply with legal or regulatory requirements, such as a warrant, subpoena, or other court order, or to protect against fraud, illegal activity, or as otherwise required or permitted by applicable domestic or international laws or legal processes. Your Personal Information may also be disclosed where necessary for the establishment, exercise, or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Marketing Purposes. We may share your Personal Information with third parties for marketing purposes if you have not opted out of these disclosures. If you do not wish for us to share your Personal Information for promotional and marketing purposes, you may opt-out of the sharing. However, should you do so, you may not be able to take part in certain marketing campaigns, promotions, or other activities conducted through the Site.
TYPE OF INFORMATION DISCLOSED
In the last twelve (12) months, we have disclosed the following categories of Personal Information to others for a lawful business purpose:
Personal Information Category |
Category of Third-Party Recipients |
Identifiers |
Affiliates, Partners, Service Providers, Internet Cookie Data Recipients (i.e. Google Analytics), Government Entities |
Protected classification characteristics |
Affiliates, Partners, Service Providers |
Commercial information |
Affiliates, Partners, Service Providers |
Internet or other similar network activity |
Affiliates, Partners, Service Providers, Internet Cookie Data Recipients (i.e. Google Analytics) |
Geolocation data |
Affiliates, Partners, Service Providers |
Professional or employment-related information |
Affiliates, Partners, Service Providers |
Inferences drawn from other personal information |
Affiliates, Partners, Service Providers |
YOUR CALIFORNIA PRIVACY RIGHTS
CCPA California Resident Rights Disclosures
Where provided for by law and subject to any applicable exceptions, California residents may have the right:
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to know the categories of Personal Information we have collected about you, our business purpose for collecting your Personal Information, and the categories of sources from which Personal Information is collected;
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to know whether we have disclosed your Personal Information for business purposes, the categories of Personal Information so disclosed, and the categories of third parties to whom we have disclosed your Personal Information;
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to receive your Personal Information in a portable, readily usable format that allows you to transmit your Personal Information to another entity without hindrance;
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to request, under certain circumstances, that we delete your Personal Information;
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to request that we correct inaccurate information that we maintain about you;
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to instruct businesses that sell Personal Information to stop doing so – we, however, do not sell Personal Information; and
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to be free from discrimination related to the exercise of these rights.
To exercise your rights, please use the Verifiable Consumer Request method described below. Please be aware that your rights are limited to the extent permitted by the CCPA.
“Shine the Light” Law
Under California’s “Shine the Light” law, California residents who provide personally identifiable information in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the Personal Information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared Personal Information for the immediately prior calendar year (e.g., requests made in 2020 will receive information regarding 2019 sharing activities).
To obtain this information from us, please contact us at the contact information provided above and write “Request for California Privacy Personal Information” as the subject of your message. Once we confirm your request, we will send you a reply e–mail within 30 days containing the requested information. Not all information sharing is covered by the “Shine the Light” requirements, and only that information which is covered will be included in our response.
OTHER STATE-SPECIFIC PRIVACY RIGHTS
State consumer privacy laws may provide (now or in the future) residents of certain other US states with additional rights regarding our use of their personal information including, for example, rights to:
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Confirm whether we process their personal data;
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Access and delete certain personal data;
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Correct inaccuracies in their personal data, taking into account the data’s nature processing purpose;
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Data portability;
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Opt-out of personal data processing for: (i) targeted advertising; (ii) sales; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.
The exact scope of these rights may vary by state. To exercise any of these rights, where applicable, please use the Verifiable Consumer Request method described below. Please be aware that your rights are limited to the extent permitted by applicable law.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. However, please note that we do not currently sell personal data triggering that statute’s opt-out requirements.
VERIFIABLE CONSUMER REQUESTS
You can exercise your legal rights by submitting a Verifiable Consumer Request to us by:
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Calling us at +1 513 360 7189;
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Emailing us at [email protected]; or
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Visiting us at 675 Gateway Blvd., Monroe, OH 45050, USA.
Only you, or someone legally authorized to act on your behalf, may make a Verifiable Consumer Request related to your Personal Information. Making a verifiable consumer request does not require you to create an account with us. California residents may only make a Verifiable Consumer Request for access to Personal Information twice in a 12-month period.
The Verifiable Consumer Request must:
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Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
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Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a Verifiable Consumer Request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will acknowledge receipt of a Verifiable Consumer Request within ten (10) days. We endeavor to respond to Verifiable Consumer Requests within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the Verifiable Consumer Request’s receipt. The response we provide 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 Verifiable Consumer Requests, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
DATA SECURITY
The security of your Personal Information is important to us. We have put in place commercially reasonable administrative, technical, and physical measures in an effort to protect the Personal Information submitted to us, both during transmission and once we receive it, and to guard that information against loss, misuse or alteration. Please note, however, that no method of transmission over the internet, or method of electronic storage, is 100% secure. For example, email sent to or from the Site may not be secure. Before submitting any personal Information to us, please be aware of these inherent risks and understand that you do so at your own risk.
ACCESSING, UPDATING, AND CONTROLLING INFORMATION
If you ever wish to access, update, change, or delete your Personal Information, you may contact us at the contact information provided above. Accordingly, at your request, we will take reasonable steps to remove your Personal Information from our databases. To help us process your request, please provide sufficient information to allow us to identify you in our records. We reserve the right to ask for additional information verifying your identity prior to disclosing any Personal Information to you. Should we ask for verification, the information you provide will be used only for verification purposes, and all copies of the information will be destroyed when the process is complete.
If you do not wish to receive update messages and/or direct marketing communications from us, you may opt-out by following any instructions included in the communication or by contacting us at the contact information provided above. To help us process your request, please include sufficient information for us to identify you in our records. Please be aware that although you may opt-out of update messages and/or direct marketing communications, we reserve the right to email you administrative notices regarding the Site, as permitted under the CAN-SPAM Act.
We will make commercially reasonable efforts to respond to opt-out requests and handle requests to access, update, change, or delete Personal Information as quickly as possible.
DO NOT TRACK DISCLOSURES
Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. The Site does not currently respond to these “do-not-track” signals. If we do so in the future, we will describe how we do so in this Policy.
SPAM
We do not participate in bulk email solicitations that you have not consented to receiving (“Spam”). We do not sell or disclose customer lists or email address lists to unrelated third parties. Except as otherwise provided herein, we do not share Personal Information with any third party advertisers.
THIRD PARTY SITES
This Policy applies only to information collected by Company through internal channels controlled by Company such as the Site and our Services. From time to time, the Site and Services may link you to other sites or applications (“Linked Sites”) that are not owned by Company. We do not control the collection or use of any information, including Personal Information, which occurs during your visit to the Linked Sites. Further, we make no representations about the privacy policies or practices of the Linked Sites, and Company is not responsible for the privacy practices of these Linked Sites. We encourage you to be aware of when you leave the Site and read the privacy policies of Linked Sites.
CHANGES TO THIS POLICY; CONSENT
We reserve the right to alter, modify, update, add to, subtract from or otherwise change this Policy at any time, which will become effective as of posting on the site. If our privacy practices change materially in the future, we will post an updated version of the privacy policy to the Site. By continuing to use the Site after such changes, you consent to such changes. We encourage you to periodically review this Policy to stay informed about how we collect, use, and share Personal Information. By using the Site, or by otherwise communicating with us online, you consent to our collection and use of your Personal Information as described in this Policy, or any subsequent version thereof.