Last Updated: May 2021
Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. We will collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law. We will only retain personal information as long as necessary for the fulfillment of those purposes. We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned. Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date. We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. We will make readily available to customers information about our policies and practices relating to the management of personal information. We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.
Types of Information Collected
We may collect and process any of the following information about you and we refer to this as “Personal Information” throughout this policy:
1. The Information You Give Us
You may give us information about yourself by using the online forms provided on the Website or by contacting us by phone, e-mail or other means. This includes, for example, filling in our ‘Contact Us’ form on our Website or when you provide your information to us in order to receive our services.
The information you give us may include email address, name, mailing address, telephone number, company name, company address, credit card information, job title, account information, and any updates to the information provided to us.
Please note that we need certain types of information so that we can provide services to you. If you do not provide us with such information, or if you ask us to delete it, you may no longer be able to access our services.
1.2 Information We May Collect About You
Each time you visit the Website we may automatically collect any of the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the internet, domain name and country which requests information, the files requested, browser type and version, browser plug-in types and versions, operating system and platform
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), 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
2. Use of Information
We, or third-party data processors acting on our behalf, collect, use and store the Personal Information listed above to enable you to receive services for which you or your company have entered into a contract with us and/or because it is in the legitimate interests of Carlton Technologies, Inc. to handle your Personal Information. More specifically, we collect, use and store your Personal Information for the following reasons:
- To register you for webinars/seminars
- To assign a password
- To ensure that content from our website and services are presented in the most efficient manner for you
- To provide you with information, products or services that you request from us or which we feel may interest you, only where you have consented to be contacted for such purposes
- To carry out our obligations arising from any contracts entered into between you and us
- To allow you to participate in interactive features, such as “Live Chat”, when you choose to do so
- To notify you about changes to our products or services and to keep you informed about our fees and charges
- To provide the service(s) you have requested
- To improve the quality and accuracy of the services
- To allow you to access and use the Website and to register for an account
- To carry out activities in the legitimate interests of Carlton Technologies, Inc., for example, pursuing debt, ensuring the security of our services and Website
- To verify your identity in order to prevent and detect money laundering and fraud
- To carry out the statistical analysis and market research
- For marketing, advertising and promotional purposes
- For the purposes of improving and maintaining our Website, preparing reports or compiling statistics in order to improve our services.
- To take other action you request when you supply the Information Such details will be anonymized as far as is reasonably possible and you will not be identifiable from the data collected.
3. Data Retention
We retain Personal Information for as long as you use the services we provide and then as required to comply with applicable laws.
4. Disclosure of Information
We will not sell, hire, lease or rent your Personal Information that we collect to any third party without notifying you and/or obtaining your consent, except as expressly set forth in this Section. Where you have given your consent for us to use your information in a particular way, but later change your mind, you should contact us and we will stop doing so.
5. Privacy Shield
5.1 Our Obligations to you Under the Privacy Shield
- Carlton Technologies, Inc. has certified that it complies with the EU-U.S. Privacy Shield Framework and the Swiss
- U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce and approved by the European Commission regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States, respectively.
- Carlton Technologies, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
- The Federal Trade Commission has jurisdiction over Carlton Technologies, Inc.’s compliance with the Privacy Shield.
- Carlton Technologies, Inc. commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and to comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
5.2 Privacy Complaints, Recourse, Enforcement and Liability
In compliance with the Privacy Shield Principles, Carlton Technologies, Inc. commits to resolve complaints about your privacy and our collection or use of your Personal Information (without charge to you).
6. Protection of Personal Information
Carlton Technologies, Inc. is committed to taking steps to protect the Information you provide to us, including administrative, technical, and physical measures — to safeguard Information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction.
Information is accessed only by authorized staff who are instructed to handle Information with confidentiality. It is protected by firewalls and standard industry security measures. We may also transmit sensitive information and transactional data using secure socket layer (SSL) encryption.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorized access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website or our products and services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7. Your Rights
You may contact us by email at [email protected] at any time, to request that we:
- Update any Personal Information which is out of date or incorrect;
- Delete any Personal Information which we are holding about you;
- Restrict the way that we process your Personal Information;
- Provide your Personal Information to a third-party provider of services; or
- Provide you with a copy of any Personal Information which we hold about you.
We will consider all such requests and provide our response within the time period stated by applicable law.
You have the right to ask us to not process your Personal Information for marketing purposes. We will inform you (before collecting your Personal Information) if we intend to use your Personal Information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Information. Alternatively, you can contact us by email at [email protected] at any time.
If you have previously given your consent to the use of your Personal Information for marketing purposes, you can choose to stop receiving marketing communications which we send to you from time to time by following the unsubscribe instructions included in such communications. Alternatively, you can opt out of such communications at any time by contacting us by email at [email protected]. You can choose to opt-out from your Personal Information being used for any purpose that differs from the purposes notified to you when we collect your personal information; or disclosed to any third party.
8. Transfers of Information
If you are located outside of the United States, the Personal Information that we collect from you may be transferred to and stored in the United States or another location outside of the EEA or Switzerland. Any transfer of the Personal Information to the United States or another location outside of the EEA or Switzerland will be in compliance with the Privacy Shield.
When you visit our websites, cookies will be placed on your computer or device to maximize your experience and to help us understand how we can improve our site. If you prefer not to receive cookies, you can set your browser to either reject all cookies, to allow “trusted” sites to set them, or to accept only those cookies from those sites you are currently on. However, turning off cookies will hinder your ability to access, use, or navigate portions of the site.
If you have any questions regarding this policy or our use of personally identifiable information on this site, please send us your questions or comments as set forth in section 11 below.
11. Contact Us