“Services” refers to CSI’s products and services accessed through the Sites, from which users can download articles and reports, subscribe to receive newsletters and publications, or contact us to learn more about our products and services.
The terms “we,” “us,” and “our” refer to CSI.
“You” refers to you, as a user of our Sites or Services.
Information We Collect about You and How We Collect It
We collect information from and about persons that access or use our Sites or Services. Information may be collected: (i) directly from you when you provide it to us; (ii) automatically when you use the Sites or Services, such information being collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies; or (iii) by third parties. When you access or use our Sites or Services, we may ask you to provide, and we may collect, “Personal Information” and “Non-Personal Information.” “Personal Information” includes your name, postal address, email address, telephone number, country, place of birth, date of birth, job title or position, company or organization name, business address, industry, IP address, education and employment history, or any other information the Sites or Services collect that is defined as personal information under an applicable law, as well as any other identifier by which you may be contacted online or offline. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.
Information Collected Through Automatic Data Collection Technologies
To use our Sites you do not need to submit any Personal Information; however, to subscribe to our newsletters or publications, you are required to submit Personal Information. As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including: (i) traffic data, location data, logs and other communication data and the resources that you access and use on our Sites; (ii) information about your computer or mobile device and internet connection, including server log data, IP address, operating system information and browser type; and (iii) if you have provided permission through your device to allow us to collect location information, we may obtain your physical location information, from technologies such as GPS, Wi-Fi, or cell tower signals (“Location Information”). You may withdraw your permission for us to acquire your Location Information, but we do not control this process. We use this information to understand usage patterns on our Sites, such as to determine the parts of our Sites visitors find most valuable. The technologies we use for automatic information collection may include:
- Web Beacons. Pages of our Sites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
When you use our Sites or Services, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: (i) analytics companies that evaluate usage of our Sites and Services; (ii) your mobile device manufacturer; or (iii) your mobile service provider.
These third parties may use tracking technologies to collect information about you when you use our Sites and Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, applications, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
The Data We Collect About You
|Identity Data.||First name, maiden name, last name, alias, username or similar identifier, unique personal identifier, passport number, marital status, title, date of birth and gender.|
|Contact Data.||Postal address, mailing address, email address and telephone numbers|
|Technical Data.||Internet Protocol address, login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on devices.|
|Profile Data.||Username, password, interests, preferences, feedback and survey responses.|
|Geolocation Data.||Physical location of device.|
We do not collect any Special Categories of Personal Data (GDPR Article 9) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about your criminal convictions and offenses, if any, except to the extent that criminal conduct has resulted in your being listed on a restricted party screening list.
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How We Use Your Personal Data
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we are about to enter into or have entered into with you or a contract between you and a third party under which you have given your consent to providing personal data.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you as a new user||Performance of a contract with you or a contract between you and a third party under which you have given your consent to providing personal data|
|To manage our relationship with you which will include:
(a) Provide you with information or services that you request from us
(b) Respond to your comments, questions, and requests, and provide customer service
(d) Asking you to leave a review or take a survey
|(i) Performance of a contract with you or a contract between you and a third party under which you have given your consent to providing personal data
(ii) Necessary to comply with a legal obligation
(iii) Necessary for our legitimate interests (to respond to our clients’ and users’ requests; to keep our records updated; and to study how customers use our products or services)
|To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(i) Necessary to comply with a legal obligation
(ii) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
|To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection||(i) Performance of a contract with you or a contract between you and a third party under which you have given your consent to providing personal data
(ii) Necessary to comply with a legal obligation
(iii) Necessary for our legitimate interests (for running our business)
|To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Sites, services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To conduct recruiting and candidate evaluation activities and to inform our employment decisions||Necessary for our legitimate interests (to recruit and hire proper and qualified candidates)|
|For legal and operational compliance purposes:
(a) monitor our compliance with this policy;
(b) detect and protect us against error, negligence, breach of contract, fraud, theft, and other illegal activity, and to audit compliance with our policies and contractual obligations
(c) evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets
|(i) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(ii) Necessary to comply with a legal obligations
(iii) Necessary for us to provide a service in furtherance of a substantial public interest
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional Offers From Us
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing or other information.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing or other informational messages at any time by contacting us by email at firstname.lastname@example.org.
Where you opt out of receiving these marketing and other informational messages, this will not apply to personal data provided to us as a result of a service or work that we performed for you or other similar transactions.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Our affiliated companies.
- Our customers.
- Our vendors.
- Our service providers.
- Other third parties to protect our legal rights or comply with legal requirements.
- Other third parties as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- Other third parties with your prior consent.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We are a service company based in the United States and provide various services for companies in the EEA, the UK and Switzerland. To perform our services and comply with our contractual obligations with our clients, we may share your personal data outside the EEA, the UK or Switzerland.
We recognize that many countries globally have regulations restricting the flow of personal data across international borders. We have put in place measures to ensure that adequate protection is provided to such data where legally mandated. Whenever we transfer your personal data out of the EEA, the UK or Switzerland, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- We comply with the US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred to the EEA, UK and Switzerland from the United States. With regard to the transfer of personal data from the EEA, UK, or Switzerland to the United States, we rely on the European Commission’s standard contractual clauses, which are currently recognized by the EU, UK and Swiss data protection authorities as an alternative data transfer mechanism, and we try to implement technical measures, like encryption, that can prevent US authorities from accessing any such transferred data.
Data Retention — How Long Will We Use Your Personal Data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
How We Use and Share Your Information
We use information that we collect about you or that you provide to us to:
- Provide you with our Sites and Services and its content, and any other information that you request from us.
- Provide you with information, products or services that you request from us.
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- Notify you about changes to our Sites or Services.
- Respond to your comments, questions, and requests, and provide customer service.
- Provide news and information we think will be of interest to you.
- Contact you and respond to any communications that you may have had with us.
- Detect and protect CSI against error, negligence, breach of contract, fraud, theft, and other illegal activity, and to audit compliance with our policies and contractual obligations.
Persons attending CSI’s Annual Customer Conference on behalf of CSI customer financial institutions and other businesses may share their own Personal Information with other attendees, including exhibitors. CSI does not view such sharing as for CSI marketing purposes nor does CSI receive any consideration for the sharing.
We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.
Information from Third Party Services
For certain Services, CSI serves as a service provider. In our capacity as a service provider, we will receive, store, and/or process Personal Information. In such cases, we are acting as a data processor and will process the Personal Information on behalf of and under the direction of the third party that contracted our services. CSI uses Personal Information that it collects indirectly in its role as a service provider for the following business purposes, without limitation:
- Delivering and providing the requested Services;
- Storing and processing data, including Personal Information, in computer databases and servers located in the United States;
- Verifying individual customers’ identity; and
- As otherwise required by law.
How We Protect Your Personal Information
CSI uses secure encryption technology to protect certain categories of personal information. To secure customer information sufficiently, we have implemented industry-accepted physical and logical security policies and procedures to safeguard against the unauthorized access, disclosure, alteration or destruction of our customers’ information. However, these measures do not guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of such security measures. Any transmission of personal information is at your own risk. By accessing or using our Sites or Services, you acknowledge that you understand and agree to assume these risks.
Your Rights Regarding the Use of Your Personal Information
You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. You can also indicate that you do not wish to receive marketing communications from us by notifying us at email@example.com.
CSI is a strong advocate for protecting the privacy of children online. Our Sites and Services are not intended to be used by children, nor do we intentionally collect Personal Information from children under the age of 18. If you are under the age of 18 years, please do not register or otherwise provide information to CSI on a Site. CSI does not sell, trade, rent or otherwise share personal information about anyone, including children under the age of 18. CSI is diligent in its compliance with laws and regulations regarding the privacy of children and complies with the Children’s Online Privacy Protection Act. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact our Data Protection Officer at the address below.
Privacy Rights of California Residents
Privacy EEA Notice Supplement for the Citizens and Residents of the European Economic Area, United Kingdom and Switzerland
CSI EEA Business Activities
Our EEA business activities are primarily in regard to determining whether inquiry subjects are on restricted party screening lists maintained by governmental authorities and other organizations, including among others FBI, Interpol, U.S. Departments of Defense, State and Treasury, the EU, Australia, Canada, England, India, Ireland, Japan, Netherlands, United Nations and the World Bank. Inquiries are most often initiated by companies with which the inquiry subjects wish to engage in business and to which the inquiry subjects have given consents to the inquiries.
Single Sign On
With regard to the transfer of personal information from the EU, UK or Switzerland to the United States, CSI relies on the European Commission’s standard contractual clauses (SCC’s) that are currently recognized by the EU, UK and Swiss data protection authorities as an alternative data transfer mechanism and tries to implement technical measures, including encryption, that can prevent U.S., authorities from accessing any such transferred information without legal process. We also comply with the Privacy Shield Frameworks as a way to articulate and illustrate our commitment to data subject privacy and provide individuals with an additional legal recourse method that is enforceable in the United States.
Privacy Shield – For EU, UK and Swiss Data That is Transferred to the United States
CSI is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC).
The following principles apply to EU, UK and Swiss personal data as described below while it is in the United States:
- Individuals have the right to access their personal data and to update or correct inaccurate information or request deletion of information that has been handled in violation of the principles.
- We may share your personal data with vendors, affiliates or other third parties as described below under “Disclosures of Your Personal Data” We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party giving rise to the damages.
- We will provide individuals with opt-out choice prior to sending marketing materials.
- Individuals wishing to pursue information rights should contact CSI at the addresses below.
- We may be required to release information in response to lawful requests by public authorities including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, CSI commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact CSI at: CSI, ATTN: Data Protection Officer, 3901 Technology Drive, Paducah, Kentucky 42001-5201 or emailed to firstname.lastname@example.org.
CSI has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1.
Links to Other Websites
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Period in which To Respond
We try to respond to all legitimate requests within one (1) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Glossary of Terms
- Lawful Basis means any of the six (6) bases listed in Article 6.1(a)-(f) of the GDPR, including those reflected in the right column of the Purposes table, above.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
You have the right to make a complaint at any time to the proper authority for data protection issues; however, we would appreciate the chance to deal with your concerns before you approach these authorities.
Communications, queries, complaints or requests to exercise informational rights can be addressed to CSI, ATTN: Data Protection Officer, 3901 Technology Drive, Paducah, Kentucky 42001-5201 or emailed to email@example.com.
Changes to this EEA Notice
Computer Services, Inc. (CSI)
ATTN: Data Protection Officer
3901 Technology Drive
Paducah, Kentucky 42001-5201
Last Reviewed: May 3, 2021