Creative Compliance Software Solutions, LLC Privacy Notice
Effective Date: March 1, 2022
Creative Compliance Software Solutions, LLC (“CCSS” or “We”) is a unique and innovative cloud-based regulatory compliance company. CCSS is committed to protecting your privacy and the privacy of its clients. This Privacy Notice describes how CCSS collects, uses, and discloses personal information. This Notice applies to any personal information you provide and any personal information we collect from other parties, including your employer.
When do we collect your information? CCSS collects personal information when:
• you contact us or we perform services for you
• we provide services for our clients
• you register on our website or email distribution lists
• you RSVP to or attend our events
• you interact with us through social media
• you apply for a job at CCSS
What information do we collect? In the course of interacting with you or providing our products and services, CCSS may collect information from you or other sources, including your employer, which may include the following:
• Name and contact information (e-mail address, mailing address, phone number, mobile number, geographic location, etc.)
• Information you provide on a job application or that is obtained under a position-related background check
• Demographic information (date of birth, gender, employment status (including job title), etc.)
How do we use your personal information? All processing of your personal information is justified under a “lawful basis” for processing, including the following:
• your consent
• processing is necessary in order to enter into or perform a contract for you
• processing is necessary for us to comply with legal obligations
• processing is in our legitimate commercial interest, except that our interest may not override your fundamental rights or freedoms
• In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required to obtain your prior consent in order to send you marketing communications.
Do we collect information from children? CCSS does not knowingly collect information from children who have not reached the age of consent under relevant data privacy laws. If we learn that we have collected personal information from a child who has not reached the age of consent, we will delete it immediately.
What Information Do We Collect Through Automatic Data Collection Technologies?
As you navigate through and interact with CCSS’s websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
• Details of your visits to CCSS’s websites, including traffic data, logs, and other communication data and the resources that you access and use on the websites.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information CCSS collects automatically is only statistical data that helps CCSS improve its websites and deliver a better and more personalized service, including by enabling CCSS to:
• Estimate audience size and usage patterns.
• Store information about your preferences, allowing CCSS to customize its websites according to your individual interests.
• Speed up your searches.
• Recognize you when you return to CCSS’s websites.
The technologies CCSS uses for this automatic data collection may include:
• Web Beacons. Pages of CCSS’s websites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit CCSS, for example, to count users who have visited those pages or for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
CCSS does not collect personal information automatically, but it may tie this information to personal information about you that it collects from other sources or that you provide to CCSS.
How long do we retain your personal information? CCSS collects and processes personal information in connection with providing its clients with various services, each of which may be subject to minimum or maximum retention periods, as required by law or CCSS’s Record Retention Policy.
CCSS also maintains personal information supplied by former clients, and CCSS also manages this information in accordance with its Record Retention Policy.
Do we disclose your personal information? We may share your personal information with CCSS’s subsidiaries and affiliates as part of the process of providing services to you or to fulfill the purpose for which you provided it. We may also share your personal information with contractors, service providers, and other third parties that you or CCSS has engaged to perform services for you or to otherwise support CCSS’s
business operations. These third parties are contractually bound to keep personal information confidential and use it only for the purposes for which CCSS discloses it to them.
CCSS may also disclose your personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CCSS’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CCSS is among the assets transferred.
How do we protect your information? CCSS protects personal information using physical, electronic, and procedural safeguards that are specifically designed to meet or exceed the requirements of applicable laws. All CCSS employees receive training on the importance of protecting personal information, and only authorized employees have access to personal information. Subcontractors and agents are contractually bound to maintain protection of personal information and are not permitted to use the information for any unauthorized purpose.
What choices do you have about your personal information or our communications? You have certain rights related to the processing of your personal information, including.
• You have the right to unsubscribe from our communications by clicking the “unsubscribe” link in our marketing emails or by contacting us.
Individuals within the European Union and California residents may have additional personal information rights and choices. Please see Your Rights under GDPR and Additional Information for California Residents for more information.
Your Rights under GDPR The General Data Protection Regulation (“GDPR”) affords certain rights to individuals in the European Union. Specifically, individuals in the European Union are entitled to the following:
The right to be informed – You have the right to know what personal information CCSS processes, how it processes that personal information, and who else may have access to your personal information.
The right to access – You have the right to request that CCSS provide you with a copy of your personal information held by CCSS. CCSS may charge you a small fee for this service.
The right to rectification – You have the right to request that CCSS correct any information you believe is inaccurate. You also have the right to request that CCSS complete any information you believe is incomplete.
The right to erasure – You have the right to request that CCSS erase your personal information, under certain conditions.
The right to restrict processing – You have the right to request that CCSS restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to CCSS’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that CCSS transfer the personal information that it has collected about you to another organization, or directly to you, under certain conditions.
If you make any such request, CCSS has one month to respond to you. If you would like to exercise any of these rights, please contact CCSS by email at privacy@CreativeCompliance.com or by mail at Creative Compliance Software Solutions, LLC, Attention: Privacy Officer, 36 Long Alley, Saratoga Springs, NY 12866.
International Data Transfers – CCSS may transfer personal information it has collected from you or about you outside of the European Economic Area (“EEA”). Please be aware that countries outside of the EEA may not have the same level of data protection as your country.
Additional Information for California Residents Under California’s “Shine the Light” law, you have the right to request and obtain from us once a year an account of your Personal Information we disclosed to third parties for direct marketing purposes. You will receive a notice that will include the categories of Personal Information that was shared (if any) and the names and addresses of all third parties with which the information was shared (if any). CreativeCompliance.com does not use technology that accommodates do-not-track signals from your browser. If you are a California Resident and would like to make a request, please contact us using the information found in the “Questions or Complaints” section below.
The California Consumer Privacy Act of 2018 (the “CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access, delete, and restrict the sale of Personal Information that CCSS may collect about its clients, customers, or visitors to its websites. The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Personal Information does not include deidentified or aggregated consumer information. If you are a California resident, you have a right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
1. Collection and Use of Personal Information
In the 12-months preceding the date the information in this section was last updated, CCSS has collected the following categories of Personal Information about consumers, as defined by the CCPA: Identifiers (such as name, postal address, and Internet Protocol (IP) address); Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); Customer Records Information (such as name and address); Protected classification characteristics under California or federal law; Internet or Other Electronic Network
Activity Information (such as information regarding a consumer’s interaction with our website); and Professional or Employment-Related Information.
CCSS obtains these categories of information from you and from our clients to whom we provide services.
2. Disclosures to Third Parties for a Business Purpose
In the 12-months preceding the date the information in this section was last updated, CCSS has disclosed the following categories of Personal Information about consumers for a business purpose, as defined by the CCPA: Identifiers (such as name, postal address, and Internet Protocol (IP) address); Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); Customer Records Information (such as name and address); Protected classification characteristics under California or federal law; Internet or Other Electronic Network Activity Information (such as information regarding a consumer’s interaction with our website); and Professional or Employment-Related Information.
We disclose the categories of personal information listed above to our affiliates and/or service providers, as required, in connection with the products and services we provide to our customers. We also disclose the categories of personal information listed above to obtain quotes or proposals.
3. Use of Personal Information
We may use or disclose the personal information we collect to:
• To provide products or services requested by you or by our clients.
• To provide, support, personalize, and develop our websites, products, and services.
• To personalize your website experience.
• To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CCSS’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CCSS is among the assets transferred.
4. Sale of Personal Information and Right to Opt Out
CCSS does not sell Personal Information as defined under the CCPA and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Please note that your right to opt out does not apply to CCSS’s sharing of data with service providers, with whom CCSS works and who are required to use the data only to perform the services they provide to CCSS.
5. Right to Know and Right to Request Deletion of Personal Information
California residents have the right to request that CCSS disclose what Personal Information it collects, uses, and sells, as well as the right to request that CCSS delete certain Personal Information that it has collected from you. Once CCSS receives and confirms your verifiable request, it will disclose to you, based on the nature of your request: the categories of Personal Information it has collected about you; the categories of sources for the Personal Information it has collected about you; CCSS’s business or commercial purpose for collecting that information; the categories of third parties with whom it shares that information; and/or, at your request, the specific pieces of Personal Information CCSS collected about you.
CCSS may deny your request to delete your Personal Information if retaining the information is necessary for CCSS or its service provider(s) to:
1. Complete the transaction for which CCSS collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of CCSS’s ongoing business relationship with you, or otherwise perform a contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with CCSS.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
If CCSS denies your request, it will provide you with an explanation of our reason(s) for doing so.
You may contact CCSS using the contact information in the Questions and Complaints section below. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.
Career Search CreativeCompliance.com includes the Careers Application webpage, which is available for those who wish to search and apply for open job positions at CCSS. Applications and other materials submitted through Application webpage are first collected and processed by a third-party vendor. By submitting an application through this website, you consent to this processing of your personal information.
Website and External Links This Privacy Notice describes the data privacy and protection policies of CCSS.
In addition, CreativeCompliance.com may contain links to other websites. This Privacy Notice only addresses your information that is received by CCSS. You are encouraged to review the privacy policies of each website you visit.
Questions or Complaints If you have any questions or complaints about this Notice, or about our data privacy or security policies in general you may email your comments to privacy@CreativeCompliance.com or contact us by mail at Creative Compliance Software Solutions, LLC, Attention: Privacy Officer, 36 Long Alley, Saratoga Springs, NY 12866 or by telephone at 1-518-584-1704.