Effective Date: April 15, 2011
This Privacy Statement (“Privacy Statement”) explains how CDP, INC (“CDP”) uses personal information (“Personal Information”) and applies to all new users who register on our site on or after the Effective Date. If you do not agree to our practices, please do not register, subscribe, create an account, purchase a training class, or otherwise interact with CDP at www.cdp-inc.com, and any individual, business partner-specific, merchant-specific, city-specific, or other area-specific sites we offer (collectively, the "Sites").
Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can reach us online at firstname.lastname@example.org. You can reach us via postal mail at the following address:
Attention: Privacy Office
8000 Corporate Center Drive
Charlotte, NC 28226
Our Privacy Statement is organized as follows:
- Types of Personal Information We Collect
- How CDP Collects Personal Information
- How CDP Uses Personal Information
- When and Why CDP Discloses Personal Information
- Cookies and Related Technologies
- Referring Friends to CDP
- Your Choices
- Accessing and Correcting Personal Information
- Security of Personal Information
- Notice to Residents of Countries outside the United States of America
- Privacy Practices of Third Parties
- Facebook Connect
- Changes to this Privacy Statement
- California Privacy Rights
1. Types of Personal Information We Collect
Personal Information is information that can be used to identify, locate, or contact an individual. It also includes other information that may be associated with Personal Information. We collect the following types of Personal Information:
Contact Information that allows us to communicate with you, such as your name, postal addresses, email addresses, social media website user account names, telephone numbers, or other addresses at which you receive communications from or on behalf of CDP.
Relationship Information that helps us to understand who you are and what types of content you might like. This includes location information related to your state/province, city, or neighborhood; areas of interest, information collected from social media interactions (such as via Facebook Connect); demographic information (e.g., birth date, age, gender); information about persons for whom you have purchased training or who have bought training for you; and information about friends who refer you or who you have referred to this site.
Transaction Information about how you interact with CDP, such as the training sessions you view or purchase; other information about how you use our Sites, email, other communications, and applications; and how you interact with CDP merchants, business partners, and service providers.
Financial Account Information as needed to process payments for CDP training that you purchase, such as your credit or debit card number, expiration date, card verification number, and billing address.
2. How CDP Collects Personal Information
We ask you for Personal Information (including Contact Information, Relationship Information, and Financial Account Information) when you register, subscribe, create an account, purchase training, or otherwise interact with the Sites or contact CDP.
We also collect Transaction Information if you contact us via telephone, email, text, postal mail, social media interaction, or other methods of communication, such as for customer support purposes.
We collect information that you provide us about other people when you purchase training for others, including those persons’ Contact Information and Relationship Information. We create transaction records of your purchase for those persons.
If you use a social media platform or your mobile device (or other method of communication) to interact with CDP or the Sites, the application may have a specific privacy statement that governs the use of Personal Information related to that application. For example, if you use a CDP mobile application and your mobile device’s settings allow it, we may collect Mobile Location Information from your device. Our application may be designed to collect information even if you are not logged into the CDP application or the Sites. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
We may receive additional Personal Information from third parties. We may use this Personal Information to enhance other information we have about you to help us better understand you and to otherwise enhance the Sites or CDP services.
3. How CDP Uses Personal Information
CDP uses Personal Information to:
- Operate and improve our Sites;
- Provide customers with offers for training, including offers based on variables such as stated and anticipated customer interests, personal characteristics, or location;
- Facilitate orders for training, including their purchase and redemption;
- Evaluate eligibility of customers for certain offers, products or services;
- Evaluate the types of offers, products or services that may be of interest to customers;
- Track purchase of training sessions and perform other analytics;
- Provide customer support, including to our merchants or business partners;
- Fulfill requests for CDP services;
- Communicate and provide additional information that may be of interest to you about CDP and our business partners, such as CDP news, special offers, announcements, and marketing materials;
- Send you reminders, technical notices, updates, security alerts and support and administrative messages service bulletins, or marketing;
- Provide advertisements to you through the Sites, email messages, text messages, applications, or other methods of communication;
- Administer surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our partners;
- Allow you to apply for a job, post a video or sign up for special offers from third parties through the Site.
4. When and Why CDP Discloses Personal Information
We will not disclose your Personal Information to third parties except to:
- Affiliated companies (e.g., subsidiaries and other companies owned by or controlled by CDP) who may only use the Personal Information for the purposes described in Section 3 above.
- Our service providers that provide services for us such as sending emails on our behalf and processing payments. Our service providers are bound by law or contract to protect the Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them.
- CDP business partners or advertisers, as part of an offer, contest, or other activity that is provided by or in conjunction with CDP and its business partners and in which you have elected to participate. For example, if you are referred to CDP from a business partner's website or through an invitation facilitated by or in conjunction with a CDP business partner, CDP may provide that business partner with Contact Information and Transactional Information to validate the referral and to support the terms of the relationship between CDP and the business partner, which may allow such business partner to contact you directly and to advertise to you.
- Effect a merger, acquisition, or otherwise; to support the sale or transfer of business assets; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, respond to a government request; or as needed to support auditing, compliance, and corporate governance functions. We may also disclose Personal Information to defend ourselves in litigation or a regulatory action, and when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate. If CDP is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
We encourage CDP business partners to adopt and post privacy policies. However, the use of your Personal Information by such parties is governed by the privacy policies of such parties and is not subject to our control.
We may also disclose information about you that is not personally identifiable. For example, we may provide our business partners or other third parties with reports that contain aggregated and statistical data about our users.
5. Cookies and Related Technologies
When you use our Sites, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. As you use our Sites and applications, your browser and devices communicate with servers operated by us, our business partners and services providers to coordinate and record the interactivity and fill your requests for services and information.
The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to our Sites by your computers or mobile devices. These servers are operated and the cookies managed by us, our business partners or our service providers.
For example, when you visit our Sites, CDP and our service providers may place cookies on your computers or mobile devices. Cookies allow us to recognize you when you return, track and target your interests in order to provide a customized experience. They also help us provide a customized experience and help us to detect certain kinds of fraud. A "cookie" is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Sites. Some cookies contain serial numbers that allow us to connect your Site activity with other information we store about you in your profile or as related to your interactions with the Sites.
Some cookies are temporary, whereas others may be configured to last longer. “Session" cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. "Persistent" cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user id if you asked to be remembered), and storing your preferences.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our Sites, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol (“IP”) addresses of the devices you use to interact with the Sites. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to our Site and the website you visit after you leave our Site, if this information is supplied to us by your browser.
In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about Site users to optimize our Sites and understand its traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Statement governs how we use that information.
6. Referring Friends to CDP
CDP enables you to refer friends to CDP. You may be eligible to earn benefits for referring friends (subject to Terms and Conditions for referring a friend and details available on our Sites). If you wish to refer friends to CDP, we provide you a unique referral link, which you can share directly with others via email, social media websites, or other communications methods. If someone clicks your link and takes a qualifying action, we may attribute that referral to you for purposes such as awarding reward credit. CDP does not collect Personal Information about the persons with whom you share your link until the persons click the link and engage directly with CDP .
7. Your Choices
We think that you benefit from a more personalized experience when we know more about you and the kinds of deals you like. However, you can limit the information you provide to CDP, and you can limit the communications that CDP sends to you.
You can manage your email preferences by logging into your account through the Sites, entering the “My Account” section, and selecting “Manage Email Subscriptions.” You can also manage your subscriptions by following subscription management instructions contained in the commercial messages that we send you. You may choose to subscribe to some types of messages, and may choose to unsubscribe from others. You may update your subscription preferences from time to time. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account and your purchases. For example, even if you have unsubscribed from our promotional email messages, we will still send you confirmations when you purchase CDP training.
You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You can opt-out of being targeted by certain third party advertising companies online at www.networkadvertising.org/consumer/opt_out.asp or http://preferences.truste.com/truste/.
You may manage how your mobile device and mobile browser share Location Information with CDP, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
You may also manage the sharing of certain Personal Information with us when you connect with us through a social media platform or application, such as through Facebook Connect. Please refer to the privacy settings of the social media website or application to determine how you may adjust our permissions and manage the interactivity between CDP and your social media account or your mobile device
If you wish to opt out of receiving offers directly from CDP business partners, you can follow the opt-out instructions in the emails that they send you.
8. Accessing and Correcting Personal Information
Keeping Personal Information about you current helps ensure that we offer you the best deals available through our merchants and business partners. You can do several things to help keep Personal Information about you current. You can access, update and delete your Contact Information, Financial Account Information, and the other information you provided to use in your profile by logging into your account and accessing the “My Account” section of the Site or sending us an email at email@example.com.
If you want to close your account or have other questions or requests, please contact us. While we are ready to assist you in managing your subscriptions, closing your account, and removing your active profile, we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous purchases on the Sites for financial reporting and compliance reasons.
We will retain your information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at firstname.lastname@example.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. Security of Personal Information
CDP has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information. For example, we use industry-standard encryption technology to secure Financial Account Information when it is being transmitted over the Internet.
10. Notice to Residents of Countries outside the United States of America
CDP, Inc. is headquartered in the United States of America. Personal Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, merchants, or service providers elsewhere in the world. By providing us with Personal Information, you consent to this transfer. We will protect the privacy and security of Personal Information according to our Privacy Statement, regardless of where it is processed or stored.
11. Privacy Practices of Third Parties
This Privacy Statement only addresses the use and disclosure of information by CDP through your interaction with the Sites. Other websites that may be accessible through links from our Sites may have their own privacy statements and personal information collection, use, and disclosure practices. Our merchants and business partners may have their own privacy statements, too. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of an offer or promotion.
13. Facebook Connect
If you are not currently registered as a CDP user and you use the Site’s Facebook connection functions, you will first be asked to enter your Facebook credentials and then be given the option to register and join CDP. Once you register with CDP and connect with Facebook, you will be able to automatically post recent CDP activity back to your Facebook wall. Please refer to the privacy settings in your Facebook account to manage the performance of your Facebook account.
14. Changes to this Privacy Statement
From time to time, we may update this Privacy Statement to clarify our practices or to reflect new or different privacy practices, such as when we add new features to our Sites. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of notice on the Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information about our privacy practices
15. California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of Personal Information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the proceeding calendar year. In particular, the law provides that companies must inform consumers about the categories of Personal Information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by CDP pursuant to Section 1798.83 of the California Civil Code, please contact us via email to email@example.com, or by writing us at the following address:
Attention: Privacy Office
California Customer Choice Notice
6911 Shannon Willow Road
Charlotte, NC 28226
Please allow 30 days for a response.