This Privacy Notice (“Privacy Notice”) describes the privacy practices of Cistera Inc. and its subsidiaries and affiliates (collectively, “Cistera” or “us” or “we”).
Cistera provides technology services to other businesses – our clients. To take advantage of our services, our clients share with us information about their individual consumers, including contact details and shopping histories. We analyze that information and develop and send communications to the consumers only at the direction of the client who provided the information, and only on that client’s behalf. We may also collect personal data for our own business purposes in connection with our business, such as business contact details of potential customers or job applicants’ resumes.
This Privacy Notice applies to:
- The Cistera.com website and any other websites or online services controlled by us and which display this Privacy Notice, and
- Information We Collect
- Information We Collect for Cistera’s Own Business Purposes
- Information We Collect from or on Behalf of Our Clients
- Cookies and Other Information Collected by Automated Means
- Automated Data Collection for Cistera’s Own Business Purposes
- Automated Data Collection on Behalf of Our Clients
- Our Use of Personal Information
- Our Use of Personal Information for Cistera’s Own Business Purposes
- Our Use of Personal Information on Behalf of our Clients
INFORMATION WE COLLECT
Information We Collect for Cistera’s Own Business Purposes
We may collect information about individuals who interact with Cistera when using our website or services (such as employees of our clients), job applicants, and other individuals.
How we collect the information
We may collect information:
- Directly from individuals
- From third party vendors, data brokers, or business partners
- From recruiters
Types of information we collect
The types of information we collect include:
- Personal and business contact information (such as name, business name, address, telephone number, email address, and mailing address)
- Payment information (such as credit card or other financial account numbers)
Information We Collect from or on Behalf of Our Clients
We may collect information about individual consumers from our clients or – at clients’ request– from their service providers. Our clients determine the scope of the information transferred to us, and the information we receive may vary by client. Typically, we may collect clients’ consumers’ contact details and demographic data, shopping histories, and details about consumers’ interactions with marketing communications.
COOKIES AND OTHER INFORMATION COLLECTED BY AUTOMATED MEANS
We, our service providers, and our business partners, may collect certain information about the use of our websites by automated means, such as cookies, web beacons and other technologies.
OUR USE OF PERSONAL INFORMATION
Our Use of Personal Information for Cistera’s Own Business Purposes
We may use personal information to:
- Provide our services to our clients
- Communicate about the products and services we offer, and respond to requests, inquiries, comments, and suggestions
- Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read)
- Operate, evaluate and improve our business, our websites, and other products and services we offer (including to develop new products and services)
- Invoice and collect payment for our services
- Establish and maintain an individual’s profile in our service
- Tailor the content we display in our communications, in our services and in mobile apps
- Administer surveys and other market research
- Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests)
- Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide
- Process employment applications
- Monitor recruiting statistics, to inform our recruitment activities
We may aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
If you submit your information in connection with job opportunities at Cistera, we will use and disclose the information to process your application (including to contact you and/or your references and former employers if appropriate), to monitor recruitment statistics, and to comply with government reporting requirements. We also retain statistical information about applicants to help inform our recruitment activities. We will process this information based on our legitimate interest of evaluating job candidates or, when you provide us with sensitive information, based on your consent.
PRIVACY PREFERENCES, RIGHTS, AND CHOICES
Individuals have certain rights and choices regarding Cistera’s processing of their personal information. Please note, however, that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing our products or services to individuals who exercise these rights, or from otherwise engaging with such individuals going forward.
Individuals whose personal information Cistera processes on behalf of a client should contact that client to exercise the rights and choices described in this section.
We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom the information pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.
For information about the rights and choices users have with respect to cookies and online tracking, please see the “Cookies and Other Information Collected by Automated Means” section of this Privacy Notice.
General Objections to the Processing of Personal Information
To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to Cistera’s use or disclosure of your personal information will mean that Cistera will not be able to provide products or services to you or to otherwise engage with you.
Access to Personal Information
You may request access to correct, amend, or delete the personal information that we maintain about you. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal information. We may reject your request to access or correct your information, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection. If you wish to exercise this right please contact us here at privacy@Cistera.com
To limit the use and disclosure of your personal information, please submit a written request to privacy@Cistera.com.
Portability of Personal Information
You may request that we transfer your personal information to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
Deletion of Personal Information
You may request that we delete your personal information. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.
You may unsubscribe from receiving marketing or other commercial emails from Cistera by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our website terms).
As further explained in the Privacy Shield Principles more fully described here, you may be entitled to invoke binding arbitration pertaining to certain residual complaints that have not been resolved by any other means.
HOW WE PROTECT INFORMATION
We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we maintain against accidental, unlawful, or unauthorized access, disclosure, alteration, use, loss, or destruction. However, we cannot guarantee that the safeguards we maintain will ensure the security of the personal information.
LINKS TO OTHER WEBSITES AND THIRD-PARTY CONTENT
We may provide links to websites and other third-party content that is not owned or operated by Cistera. The websites and third-party content to which we link may have separate privacy notices or policies. Cistera is not responsible for the privacy practices of any entity that it does not own or control.
CHANGES TO OUR PRIVACY NOTICE
Cistera reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.
We will retain personal information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. We will then destroy the personal information or anonymize the information, in accordance with applicable law.
HOW TO CONTACT US
You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or if you wish to access, delete or correct you information, by emailing firstname.lastname@example.org