C1st Tech Privacy Policy
I. Introduction
Your privacy is important to us. The purpose of this Privacy Policy Statement (“Privacy Policy”) is to inform you how C1st Technologies, LLC, a Colorado limited liability company, together with its holding company, affiliate companies, and direct or indirect subsidiaries (“C1st”, “us”, “we”, or “our”), collects, uses, shares, and protects your information when you access our main website (www.c1sttechnologies.com) and all related websites we provide (collectively, the “Website”), seek out and engage us for software and other Services (collectively, our “Services”), or otherwise interact with us online and offline, in accordance with governing data privacy laws, regulations, and other requirements, including, but not limited to, the California Consumer Privacy Act (“CCPA”) Cal. Civ. Code §§ 1798.100 et seq. and the corresponding regulations codified in §§ 999.300 – 999.341 of Title 11 of Division 1 of Chapter 20 of the California Code of Regulations (“Privacy Laws”).
If any part of this Privacy Policy conflicts with the Privacy Laws and/or other applicable legislation, the law(s) shall prevail.
Our Privacy Policy is designed to inform you about how we collect, use, protect, and disclose the information that we collect and/or receive about you. It also explains how you can manage the privacy of your Personal Information. Please note that our Privacy Policy does not govern the practices of third parties, including our partners, third-party service providers, and/or advertisers, even when those services are branded as, or provided on behalf of, C1st. Information collected from you by others, such as third-party websites that you access through links on the Website, are governed by those entities’ privacy policies. Please review the privacy policies of any third-party websites for information on how those entities collect and use your information.
By accessing or using our Website and/or Services, you agree to the terms of this Privacy Policy. Please do not access or use our Website or our Services if you do not wish for your Personal Information to be used as described within this Privacy Policy.
II. Personal Information Collection
“Personal Information”: means any information that identifies, relates to, describes, or could be reasonably associated or linked with a particular person or household. It also includes other information that may be associated with you, such as your Usage Data, location, preferences, or interests, if that information can be used to identify you, your household, or your device, or any other information as otherwise defined under applicable law.
We aim to only collect such Personal Information which is reasonably necessary for the purposes in question. Such Personal Information may include identification information (name, job title), contact details (e-mail address, mailing address, and telephone number), and other information collected by cookies.
The types of Personal Information we collect about you depend on your interactions with us and are described in more detail below.
· Individual Identifiers: This information includes your name and contact information, such as mailing address, phone number, and email address.
· Usage Data: We may also collect Personal Information on how you access and use our Website (“Usage Data”). This Usage Data helps us understand how users interact with our Website, and may include information such as your computer’s IP address, cookie information, browser type, browser version, aggregate Website usage metrics such as total number of visitors, pages viewed, and usage patterns within the Website, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, device information such as device settings, user preferences, and unique device identifiers, and other diagnostic data.
Business Information: Please note that C1st is a Technology Solutions Provider. As a business-to-business provider, much of the information we collect is related to the Services that we provide to companies that are our business customers. As such, the information we collect is largely needed for our business customers to fulfill their orders and use our Services. As part of that process, we may need to collect the identifying information of those individuals who are our business customers’ representatives or agent, or our business customers’ Users of our Services, such as business contact or employment information of a business customer’s representative. In such situations, this information is regarded as “Business Information” as it relates to the company that has engaged us and not to the individual who contacted us on the company’s behalf.
In certain situations, we may collect information from individuals who are not serving as a business customer’s representative, agent, or User of our Services. For instance, we may collect information from individuals when they choose to visit our publicly-available Website, or if they contact us at our email, postal address, or telephone number. In those instances, the information they provide would be “Personal Information” rather than “Business Information.”
Personal Information Collected Over the Last 12 Months
Other than those listed above, C1st did not collect any other types of Personal Information from individuals over the last 12 months.
III. How We Collect Personal Information
We collect the Personal Information you directly provide to us, information collected when you use our Website or services, and information received from third parties. Specifically, Personal Information may be collected from you in one or more of the following ways:
a. when you visit and use our Website, information about you may be collected via the use of cookies;
b. through your own submissions and interactions with us, including via the Website’s Contact Us function, and by mail, email, telephone, or other means of contact;
c. through your employer’s ongoing business relationship with C1st in which your information is used as part of that relationship; and
d. from other third-party sources.
Information We Obtain When You Use Our Services
As noted above, we collect certain information from you through your use of our Services. For instance, if your company enters into a contract with us or engages with us to provide certain Services, we will collect your information – typically Business Information – as part of that process so that we can furnish our Services to your company. We may collect information in relation to how you use our Website (for example, aggregate metrics on how often certain pages on our Website are accessed and viewed).
Information We Automatically Collect
We automatically receive and store certain types of personal information whenever you interact with our Website. This information includes your IP address, browser type, and pages you visit when you interact with our Website. Some of these cookies may record your preferences, track the use of our Website, clicks on and to our Website, and clicks to third-party hyperlinks on our Website. We may also use these technologies to monitor web traffic, improve the Website, understand how our users interact with the Website, and make the Website easier to use and more relevant.
IV. Use and Disclosure of Personal Information
1. We collect and use your Personal Information for various purposes:
a. the provision of C1st’s products and Services;
b. the fulfilment of a contract to which C1st is a party or has an interest;
c. C1st’s administrative purposes including, without limitation, payment processing, account management, and order processing;
d. the direct marketing of C1st’s products and services, as further described below;
e. to respond to any enquiry submitted by you, or on your or your company’s behalf, including, without limitation, redirecting your enquiry to the relevant internal or external person or department, and as necessary to investigate and formulate such a response;
f. as required to enable C1st to comply with its obligations under any law, regulation, guideline, code of practice, or contract including, without limitation, pursuant to the requirements of any bank or other finance institution, court, arbitral tribunal or government authority;
g. for the collection of monies owed for products and services provided;
h. to prevent, detect, investigate and respond to activities which may be illegal or in breach of our policies including, without limitation, the Website Terms of Use;
i. Website management including, without limitation, access facilitation, content improvement and usage statistics;
j. as permitted or required by law;
k. any other purpose for which you request, authorize, or give your consent; and
l. any purpose directly related to those purposes set out above.
2. We shall obtain your consent before using your Personal Information for a purpose materially different to those listed above.
V. Business and Other Purposes for Our Collection and Use of Your Personal Information
C1st collects, processes, and uses your information to facilitate your use of our Website. We therefore will collect and use your information for a variety of reasons, including:
Contract Performance: This would apply when our use of your Personal Information relates to the provision to you or by you, or your company, of products or services, or communications regarding the same including, without limitation, when we use your Personal Information to take and handle orders, deliver products and services, and process payments.
The legitimate business interests of C1st and our customers: The collection and processing is in our legitimate business purposes or the legitimate interests of a third party. This would include, without limitation, when your Personal Information is used for administrative purposes, for the provision of our products and Services to third parties, to assist with fraud prevention, improve the security of our networks, assist with enhancing the physical security of our customers, and reporting suspected criminal activity to law enforcement, or for direct marketing.
Compliance with a legal obligation: This applies when we use your Personal Information in order to exercise our legal rights or to comply with our obligations under any law, regulation, guideline, code of practice, or contract including, without limitation, pursuant to the requirements of any bank or other finance institution, court, arbitral tribunal or government authority.
Other legal bases as permitted under applicable laws, regulations, or other legal authority.
VI. Sharing Your Personal Information
We may share or disclose your personal information to help provide our Services to you. For instance, we may share your information with our affiliated companies and service providers to respond to your requests or to provide customer service. We may also provide your Personal Information to third party service providers who assist us in providing our Services. For example, we may provide your information to third party IT service companies that host our serves and our Website .
1. Generally, your Personal Information will be kept confidential. We may, however, disclose or share your Personal Information for the following purposes:
a. To facilitate and improve the quality of our Services;
b. To protect our users and network against fraud and security threats;
c. as required to fulfill the purposes outlined in this Policy;
d. to protect the rights and property of C1st, its employees, officers and shareholders including, without limitation, as required to recover monies owed to C1st, to respond to any potential breach of our policies, or to defend or pursue any civil or criminal claim, demand or complaint made by or against you or any third party;
e. to satisfy the requirements or request of any governmental authorities, legal bodies or other persons or entities as required or permitted by law;
f. as a result of the sale, acquisition, transfer, change of control, re-structuring, liquidation or sale of our business or assets;
g. as required or permitted by law; and
h. any other party to whom you authorise us to disclose your Personal Information.
We may share your information with the following types of entities and third parties:
· C1st Affiliated Companies: we may share your information within the C1st and C1st employees, officers, advisers, consultants, and representatives as related to providing and maintaining our Services.
· Service Providers: We use certain fulfilment service providers, companies, individuals, and agents to facilitate and help us provide our services. Such service providers perform tasks, services, or functions on our behalf, or assist us in analyzing how our services are used or delivered. These service providers may include, cloud-based storage and web-hosting providers, and other vendors that assist us in providing our services. These service providers are granted access to your information only to perform these tasks on our behalf and are contractually obligated not to disclose or use it for any other purpose.
· Marketing Providers: we also work with marketing providers to assist us with our direct marketing and advertising efforts.
· External Professional Advisors: We engage with certain professional advisors to assist in provision of our services and ensuring our operations are in accordance with applicable laws. C1st engages legal, accounting, and financial advisors.
· Law Enforcement or Other Government Authority: We may from time to time be required to provide information to law enforcement or other governmental authorities pursuant to a warrant, court order, or other lawful process.
Categories of Personal Information Shared in the Preceding 12 Months
C1st shared the categories of Personal Information described above for the described business purposes in the preceding 12 months.
Categories of Personal Information Sold
We do not sell your Personal Information to third parties. Please note that “sale” of Personal Information does not include those instances when such information is part of a merger, acquisition, or other transaction involving all or part of our business. If we sell all or part of our business, make a sale or transfer of assets, or are otherwise involved in a merger or other business transaction, we may transfer your Personal Information to a third party as part of that transaction. If such transaction materially affects the manner in which we use your Personal Information, we will notify you of such change prior to its implementation.
VII. Cross Border Data Transfers
C1st provides Services across the globe. Consequently, your Personal Information may be transferred to, and/or maintained on, computers located outside of your place of residency by C1st or third parties that process Personal Information for us for the purposes describe in this Policy. As a result, your information may be subject to access requests from governments, courts, law enforcement officials and other lawful authorities in another jurisdiction according to its laws. Subject to the applicable laws, we will use reasonable efforts to ensure that appropriate protections are in place to maintain protections on the personal information.
The risks of transferring Personal Information into and out of your place of residency include the possibility of data breaches and loss. Further, the jurisdiction to which your Personal Information may be transferred may not have in place data protection laws which are substantially similar to, or serve the same purposes as, the Privacy Laws, as such your Personal Information may not be protected to the same or similar level as in your place of residency.
VIII. Children’s Privacy
Our services, including our Website, are meant for adults 18 years old and over. We do not knowingly or intentionally collect personal information through the Website from children under thirteen (13) years of age. If you are under 18 years of age, do not attempt to register for or use any of our services, including our Website, and do not provide us any personal information about yourself. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us with personal information, please contact us as described below. If we become aware that a minor has provided us personal information or otherwise used our services in violation of the Policy, we will take steps to remove that information.
IX. Security
1. We take the security and protection of your personal data very seriously and use reasonable, appropriate, and customary procedures and technologies to help protect the confidentiality of any Personal Information we collect. As such, we:
a. store your Personal Information on secure servers and have put in place appropriate security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal of your personal data;
b. shall, as far as reasonably possible, restrict the disclosure of your Personal Information to those employees directly involved in the purposes detailed herein; and
c. provide employee training on Personal Information handling.
2. However, no website, network, or system can be absolutely protected against intentional or malicious intrusion attempts despite our precautions. Furthermore, C1st does not control the devices, computer or network through which you access the Website or over which you may choose to send Personal Information or other information to us, and therefore cannot prevent potential interceptions or compromises to your information while in transit. C1st makes no guarantee as to the security, integrity or confidentiality of any information transmitted to or from the Website. C1st is committed to safeguarding your information to the best of its ability but cannot guarantee the security of electronic communications or transmission made over the Internet.
X. Retention of Personal Information
We will only retain your Personal Information for as long as it is necessary to fulfil the purpose for which it is collected, or as may be required or permitted by law. Thereafter commercially reasonable and technically feasible measures shall be taken to irrecoverably or irreproducible delete or otherwise destroy your Personal Information.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
XI. California Residents’ Privacy Rights
California residents are afforded certain rights related to their information under California law known as the California Consumer Privacy Act (“CCPA”). C1st aims to take reasonable steps to allow California residents to access or delete your Personal Information and exercise other applicable rights. C1st informs you that California residents may be entitled to the following in relation to their information:
o Right to Access: California residents may obtain access to their Personal Information upon simple request – that is, you may receive a copy of such information upon receipt of a verifiable request, along with other information related to the collection or processing.
o Right to Disclosure of Direct Marketers: to have access upon simple request the categories and names/addresses of third parties that have received Personal Information for direct marketing purposes.
o Right to Information About Collecting, Selling, Sharing, or Disclosing Personal Information: upon receipt of a verifiable request, California residents may obtain a list of:
1. The specific pieces of your personal information C1st holds;
2. The categories of personal information collected about you, sold to third parties, or disclosed to third parties for business purposes;
3. The categories of personal information sold within the last 12 months;
4. The categories of sources from which personal information is collected;
5. The business or commercial purpose for collecting or selling personal information; and
6. The categories of third parties with whom personal information is shared, sold, or disclosed for a business purpose.
o Right to Opt-Out of the Sale of Personal Information: California residents have the right to opt-out of the sale of their personal information under certain circumstances. As noted elsewhere in this Policy, we do not sell your personal information.
o Right to Deletion: to obtain the deletion of your personal information in the situations set forth by applicable data protection law and upon receipt of a verifiable request.
o Right to Non-Discrimination. As defined under relevant law, you have a right to non-discrimination in the Services or quality of Services you receive from us for exercising your rights.
Submitting a Verifiable Privacy Rights Request
As described above, California residents have certain rights to access, delete, or otherwise control the use, collection, and/or disclosure of their information. C1st will respond to an individual’s “verifiable request” to exercise their rights under such laws, that is, where we have received a request purporting to be from a particular individual, and we have been able to verify the individual’s identity.
When making a rights request, we will ask you to provide information about yourself so that we can verify your identity as part of this process. This information may include your name, email address, account information, and any other information deemed necessary by C1st to reasonably verify your identity, to ensure that your information is not shared with anyone impersonating you. Once we have verified your identity, we will work to fulfill your request in a timely manner. Please note there may be some situations in which we are unable to fulfill your request, such as if we cannot find any information about you within our systems. Additionally, we may not be able to honor a deletion request in some situations, such as if your information is necessary to fulfill the services you requested or meet a legal obligation. We will inform you whether we can fulfill your rights request.
We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm a request for your information is a “verifiable request.”
Under California law an individual can appoint an “authorized agent” to make certain verifiable requests upon their behalf, such as the right to know what information we collect about the individual or to request deletion of the individual’s information. An “authorized agent” may submit a request on behalf of a California resident who has authorized the agent to act on their behalf. Because the security and privacy of your information is paramount, we will ask that you identify such persons and directly confirm that such persons are authorized to act as your agent and exercise your applicable rights under California law in such situations. This may require us to contact you directly and alert you that an individual has claimed to be your agent and is attempting to access or delete your information. We will also independently verify your identity to ensure that an unauthorized person is not attempting to impersonate you and exercise your rights without authorization. We will not share your information or honor any other requests in those situations where you cannot or do not grant permission in writing for an identified authorized agent to act on your behalf, or where we cannot independently verify your identity.
Please note we will not be able to comply with your request in certain circumstances, for example where your request is manifestly unfounded or excessive, or where we are unable to verify your identity.
You may submit a verifiable request via the following:
By:
Email, at info@c1sttechnologies.com
toll-free number: (720) 996-0668 (CA residents only)
Your California Privacy Rights Regarding Direct Marketing Information
From time to time we would like to share information with you regarding our projects, services and products by using your name and contact details to send you marketing materials. To do this we require your express consent If you wish to opt out of any or all direct marketing communications please let us know via the Contact Details herein. California residents have the right to request information from a company regarding the manner in which it shares certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set forth above.
Under California law, request to receive the following information:
The categories of information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year;
The names and addresses of the third parties that received the information; and
If the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
To make such a request, please send an e-mail to info@c1sttechnologies.com or write to us at 1801 Broadway, Suite 522 Denver, CO 80202. Please provide sufficient information for us to determine if this applies to you, verify your identity, and attest to the fact that you are a California resident. Please also provide a current California address for our response. Any such request must include “California Privacy Rights Direct Marketing Information Request” in the first line of the description, and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the address provided for this purpose below.
Note that responsive information may be provided in a standardized format that is not specific to you.
“Do Not Track” Signals
We do not support “Do Not Track,” which is a preference you can set in your web browser to inform websites that you do not want to be tracked. We do not track your behaviour over time and across third party websites or other services. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser.
Third parties may collect data relating to you. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
More Information About Your Rights as a California Resident
Deletion Right Request
As we mentioned above, California residents have the right to request that we delete their Personal Information that we collect and retain about them, provided certain exceptions do not apply. If we receive and confirm a verifiable consumer request we will delete your personal information from our records, unless an exception applies, and direct our service providers to do the same.. Please note that we may deny your deletion request if retaining the information is necessary for us or our service providers to:
· Complete the transaction for which we collected the Personal Information, provide the goods or service that your requested, take actions reasonably anticipated within the context of our business relationship, or fulfill our contractual obligations with you;
· Detect security incidents, protect against malicious activity, and prosecute those involved;
· Debug products to identify and repair errors that may impair existing intended functionality;
· Exercise free speech, ensure the right of another individual to exercise free speech rights, or another right as guaranteed by law;
· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the requested deletion might seriously damage the chance of that research’s achievement, if informed consent was previously provided;
· Enable solely internal uses that are reasonably aligned with individual expectations based upon our existing relationship;
· Comply with a legal obligation;
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Additionally, please note that upon such deletion of the requested Personal Information, it may not be possible for us to provide our services and products to you or any company you represent.
Employee Exception
Please note that C1st is not required to provide or delete any of the above information to its employees, applicants, agents, or contractors, along with information related to employee emergency contact information.
XV. Third Party Websites
Our Privacy Policy is designed to advise you about how we collect, use, protect, and disclose the information that we collect and/or receive about you. The Website may contain links and references to external websites not owned by us, including plugins to social media sites such as Facebook, Instagram and Linkedin, and equally external websites may contain links or references to the Website or C1st (“External Websites”).
As such, this Privacy Policy does not govern the practices of third parties, including partners, third-party service providers, and/or advertisers, even when those services are provided on our behalf or in partnership with us. Information gathered about you by others are governed by those distinct entities’ privacy policies. We are not responsible for the privacy practices of the External Websites. Therefore, we strongly recommend that you check and review the applicable terms, conditions and privacy policies of the External Websites to determine how they will handle your personal data or other information collected from you.
We exercise no control over and assume no responsibility for the content, privacy policies or practices of any third party site or service.
XIII. Contact Details
If you, at any time, wish to:
a. enquire about our privacy policies, or about how we may collect, manage, protect and/or process your Personal Information;
b. complain about the way we manage, protect and/or process your Personal Information;
c. access or correct your Personal Information in C1st’s control or possession;
d. exercise any other rights you have under the Privacy Laws; or
e. withdraw your consent for C1st to collect, use, disclose and/or process your Personal Information;
please contact us by email at info@c1sttechnologies.com, or by telephone at Tel: (720) 996-0668, or by post at 1801 Broadway, Suite 522 Denver, CO 80202. Please indicate in the subject header the nature of your correspondence.
XIV. Changes to Privacy Policy Statement
This Privacy Policy Statement may be amended, supplemented or otherwise modified (“Changes”) by C1st at its discretion and without prior notice. These Changes will be effective immediately upon publication on the Website. You are encouraged to visit the Website from time to time to ensure that you are well informed of our latest privacy policies.
XV. Miscellaneous
This Privacy Policy Statement has been prepared in English. In the event that this Policy is translated into any other language the English language version shall prevail.
XVI. Difficulty Accessing Our Privacy Policy?
Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us at the above-listed contact information to inquire how they can obtain a copy of our policy in another, more easily readable format.