PRIVACY POLICY – CTM INTERACTIVE WEBSITE AND MARKETING COMMUNICATIONS

CTM Interactive and its affiliates (“CTMi,” or “The Company,” or “we,” or “us”) are committed to protect the Privacy of Personal Information provided to us by those who visit and browse the its website and other marketing communications as defined below (“Visitor”) and to those who take action such as requesting information, support, sales proposals, or subscribe to blog and/or other ongoing communications (“Subscriber”).  We shall refer to Visitors and Subscribers collectively as “Users”.

This Privacy Policy informs users of the Site and other CTMi marketing communications about what data we collect, how we might use and share that data, how the User can correct or change the information and/or the storage and the processing of that data.

WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy applies to information that we collect when Users visit our website, https://www.ctminteractive.com/ ; (ii) use our mobile applications, made available by us for use on or through computers and mobile devices that link to this Privacy Statement; (iii) visit our branded social media pages; (v) receive communications from us, including emails, phone calls or texts; (vi) register for, attend and/or otherwise take part in physical or digital events that we might produce, offer or sponsor. We will refer herein to these collectively as our “Marketing Communications Services,” or “the Services.”

In regard to the Personal Information we collect directly from the Site or other Services, or from external third party sources, CTMi is a data controller. In this capacity, we determine the purposes for which and the manner in which the Personal Information we collect is to be processed. “Personal Information” is any information relating to an identified or identifiable natural person.

This Privacy Policy does not apply to data we process and Personal Information we collect in the role of a data processor or service provider on behalf of our business customers, such as information we receive and process through CTMi’s Activ8 Plus Platform and related services.  For the Privacy Policy that relates to the processing of data on our Activ8 Plus Platform, please refer to the Privacy Policy at https://www.ctminteractive.com/privacy-policy . For privacy information related to our respective business customer’s use of the Activ8 Plus Platform within with their marketing activities, Users should reach out to the respective business customers directly.

 

PERSONAL INFORMATION WE COLLECT DIRECTLY.

The channels and methods of collection are as follows.

  1. Site usage – When visitors to the site or engaging with us in other marketing communications use the Services or fill out forms, register or subscribe by other means, we may provide them with opportunities to sign up to receive specific information or Services, download content, or register for an event, and we may ask for their contact information (e.g., name, title, company name, company address, phone number or email address). We also automatically collect information as described below.
  2. Your communications with us –  We collect Personal Information from Users such as email address, phone number, or mailing address when such users request information about our Services, register for our newsletter, request customer or technical support, apply for a job or otherwise communicate with us across the full range of our marketing communications.
  3. Social media content – We may offer forums, blogs, or social media pages. Any content that Users provide on these channels will be considered “public” and is not subject to privacy protections.
  4. Personal Information collected from others – We may also receive Personal Information from third parties who provide us with contact information for sales prospects or leads. When acquiring information from third parties, we obtain contractual commitments from the third parties that the information was acquired lawfully and with the compliant level of consent.

HOW DOES CTM INTERACTIVE USE PERSONAL INFORMATION?

We use Personal Information that we collect about Users of the Services or information that they provide to us, for a range of different business purposes, including:

  1. Providing information and Services requested by the User –  We may use the Personal Information to fulfill requests for Services, or information that that the User might request, including information about potential or future Services, including to: (a) generally manage that User’s information and accounts; (b) respond to questions, comments and requests; (c) provide access to certain areas and features of the Services; (d) link or combine information we get from others to help understand a respective user’s needs and provide her/him with better Service;  and (e) allow Users to register for events, participate in a contest or promotion, post in a forum or participate in webinars, and provide related information and communications.
  2. Administrative purposes –  We may use the Personal Information about Users for administrative purposes, including, without limitation, to: (a) measure interest in the Services; (b) perform internal quality control; (c) maintain and improve our Services; (d) verify identity; (e) send communications regarding the Services, the User’s account if registered or subscribed, or any changes to any Company policy or terms of use; (f) prevent potentially prohibited or illegal activities and fraud; (g) monitor and analyze trends, usage and activities in connection with our Services, (h) enforce our Terms of Use, (i) promote safety and security of the Services and in protecting our rights and the rights of others.
  1. Marketing products and services – We may use the Personal Information to provide Users with materials about offers, products and services offered by us, including new content or information about future services. We may provide Users with these materials by phone, postal mail, facsimile, text or email, as permitted by applicable law. Such uses include: (a) to curate content, advertisements, and offers; (b) to notify Users about offers, products, and services that may be of interest to them; (c) to provide Services; (d) for other purposes disclosed at the time that such respective Users provide Personal Information; or (e) otherwise with her/his consent. Users who do not wish us to use their Personal Information for marketing purposes, may contact us at any time to opt out of the use of their Personal Information for such purposes, with the steps for such opt out clearly described below.
  2. Research and development. We may use Personal Information to create non-identifiable information that we may use in respective analyses, or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products, processes and services.
  3. Deidentified and aggregated data –  We may use Personal Information and other information about respective Users to create deidentified or aggregated information, such as deidentified demographic information, deidentified location information, information about the computer or device from which Users access the Site or other online Services, or other analyses we create. Deidentified or aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Deidentified or aggregated information is NOT Personal Information, and the Company may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within CTM Interactive and with third parties for our or their purposes in a de-identified or aggregated form that is intently designed to prevent identification of Personal Information.
  4. Public content – In regard to Users who post any content to our website forums or open discussion/comment features, we may publish this content and make it generally available to other Users of the Site or other Services.
  5. Complying with legal obligations – We may use Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligation under applicable laws to protect our rights or is necessary to protect against misuse or abuse of our Sites or Services, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
  6. Other Uses – We may use Personal Information for other purposes disclosed fully to Users at the time they provide Personal Information and express consent.

 

 

WITH WHOM DOES CTMi SHARE PERSONAL INFORMATION?

We may share your Personal Information as follows:

  1. Service Providers – CTMi may share Personal Information with our service providers that we have retained to perform Services on our behalf including (a) provision of IT and related Services; (ii) provision of information and Services you have requested; (b) payment processing; and (c) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. The Company has executed appropriate contracts with our service providers that prohibit service providers from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
  2. Business Partners – From time to time, CTMi may partner with other companies to jointly offer products, services or programs (such as webinars, events or downloadable content). If you purchase, specifically express interest in, or register for a jointly-offered product, service or program from or through CTMi, we may share your Personal Information with our business partners. We do not control our business partners’ use of shared Personal Information and/or their use of such Personal Information will be in accordance with their own privacy policies. If a User does not wish for her/his Personal Information to be shared in this manner, then she/he may opt not to purchase or specifically express interest in a jointly offered product or service.
  3. Affiliates – We may share personal information with our own affiliated companies.
  4. Advertising Partners – Through our Services, we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.
  5. Protection of CTMi and others – We may disclose Personal Information about a respective User: (a) if we are required to do so by law, court order or legal process; (b) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (c) under the discovery process in litigation; (d) to enforce The Company’s policies or contracts; (e) to collect amounts owed to CTMi; (f) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (g) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
  6. Security – In addition, from time to time, server logs and other systems may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, records containing Personal Information may be shared with service providers, third parties and law enforcement bodies in order that they may prevent fraud and/or identify users in connection with their investigation of the unauthorized activities.
  7. Business Transfers. We reserve the right to disclose or transfer any information we have about respective Users in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding).

WHAT DEVICE AND USAGE DATA DOES CTMi PROCESS?

We use common information-gathering tools for collecting usage data, cookies and similar technologies to automatically collect information that may contain Personal Information from the User’s computer or mobile device as he/she navigates our Sites or use our Services.

  1. Cookies and other tracking technologies in our Services – As Users navigate the Sites and use the Services, certain passive information may also be collected through the use of cookies and other tracking technologies to obtain information about that User’s computer, device, browsing actions, and patterns. This includes IP addresses, cookies IDs, navigational data, contents clicked, the name of the domain and host from which the User access the Internet, the browser software and operating system she/he uses, browser settings, device type and similar information, the date and time the User accesses our Services and other device identifiers. This type of information is used for the purposes of gathering data to provide improved administration of our Services and to improve the quality of User experience when interacting with our Services (see Your Privacy Rights section below for more information).
  2. A cookie is a small text file that a website saves on the User’s computer or mobile device when he/she visits the website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, to develop a record of the User’s online activity. When a User visits our Sites, we or an authorized third party may place a cookie on the User’s browser and/or device, which collects information, including Personal Information, about his/her online activities over time and across different sites. Cookies allow us to track usage, determine that respective User’s browsing preferences and improve and customize browsing experience.
  3. We use both session-based and persistent cookies on our Sites. Session-based cookies exist only during one session and disappear from the User’s computer when the browser is closed, or when the computer or device is turned off.  Persistent cookies remain on the User’s computer or device after the browser is closed and/or the computer or device is turned off. Users can control the use of cookies at the individual browser level, but choosing to disable cookies may limit the use of certain features or functions on our Services.
  4. Types of cookies on our Sites.
  5. Essential Cookies – These cookies are necessary for the Sites to function and cannot be switched off. Some examples include: session cookies needed to transmit the website, authentication cookies and security cookies. These cookies also support certain features on the Sites, such as the live chat feature. Users can set their browser to block or alert you about these cookies, but some parts of the Sites will not then work.
  6. Functional Cookies – These cookies enhance functions, performance and services on the Sites. They allow us to count visits and traffic sources so we can measure and improve the performance of our Sites. Functional cookies also allow us to improve how our Sites function and to help us provide you with more relevant communications, including marketing communications. They help us to know which pages are the most and least popular and see how visitors move around and use the Sites. We may use our own technology or third party technology to track and analyze usage information to provide enhanced interactions and more relevant communications and to enable certain features on the Sites.
  7. Targeting Cookies. These cookies track activity across websites in order to understand a User’s interest, and to direct specific marketing to them.  Targeting and advertising cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.
  8. To change cookie settings and preferences for the Site that a User is visiting, she/he can use the Cookie Settings link that will appear at bottom of the webpage, if and when The Company is indeed utilizing Cookies at any respective time. If no such link appears on the webpage, then Cookies are not in use on the Site.
  9. Web beacons – We may also use web beacons (sometimes called “pixel tags” or “tracking pixels”). These are contain a unique identifier that is embedded in our Sites and in our emails or other marketing communications that are sent through our Services. This allows us, for example, to monitor the traffic patterns of users from one page within our Site to another, to track access to the communications sent through our services, to understand whether a User has come to our Sites from an online advertisement displayed on a Third-Party website or whether a User has viewed advertisements on our Sites or through the Services, or to improve our Sites’ performance. For more information about cookies, and how to disable them, please see “THE USERS’ PRIVACY RIGHTS AND YOUR PRIVACY CHOICES” below
  10. SDKs – We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you.
  11. Social Media Features – CTMi may collect Personal Information to enable individuals to use online social media resources offered either by the Company or a third party. We may also enable Users to use these social media resources to post or share Personal Information with others. When using social media resources, the User can and should take into careful consideration what Personal Information she/he shares with others. In addition, social media buttons such as Facebook, LinkedIn, Twitter, Instagram and YouTube (these might include widgets such as the “share this” button “or links to CTMi company pages on 3rd Party social media sites, or other interactive mini-programs) may be on our Site. These features may collect your IP address, which page the User is visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. A User’s interactions with these features apart from her/his visit to our site are governed by the privacy policy of the company or other 3rd party providing it.
  12. Analytics – We may also use Google Analytics and Google Analytics Demographics and Interest Reporting and other similar providers to collect information regarding User behavior and demographics on some of our Sites, and to develop website content. For more information about Google Analytics, please visit google.com/policies/privacy/partners/. Users can opt out of Google’s collection and processing of data generated by their use of the Services by going to http://tools.google.com/dlpage/gaoptout.
  13. International data transfers – We store Personal Information sent or collected via or by us in the United States. This applies to data collected or sent to us via the cloud, our servers, or the servers of our service providers. In regard to data sent or collected by us from outside the United States, such Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, each User consents to the storage of her/his Personal Information in the United States, and to the access by outside authorities described here.

WHAT SECURITY MEASURES DOES CTMI HAVE IN PLACE?

The security of all Personal Information provided by Users is important to us, and we take reasonable steps designed to protect their Personal Information. However, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while we strive to protect each and all Users’ Personal Information, we cannot ensure or warrant the security of information you transmit to CTMi. Each individual User is responsible for maintaining the secrecy of her/his own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify us at dataadmin@ctminteractive.com .

HOW LONG DOES CTMi RETAIN PERSONAL INFORMATION?

We retain the Personal Information as described in this Privacy Statement for as long as a User may use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

ARE CTMI’S SITES AND SERVICES FOR CHILDREN?

Due to the nature of our business, Services are not marketed to or intended for minors under the age of 16. The Company does not knowingly solicit or collect Personal Information from children under the age of 16.  If a parent or guardian believes that her/his child has provided us with Personal Information without parental consent, then such individuals should contact us by using the Contact Us at dataadmin@ctminteractive.com, or using additional contact information provided below and we will take steps to delete such Personal Information from our Services.

THE USERS’ PRIVACY RIGHTS AND YOUR PRIVACY CHOICES

The Privacy Right or all Users are an important priority to CTMi.  We have established these procedures to help protect them.

  1. Opt-out – Where a User has consented to our processing of Personal Information, such individual may withdraw that consent at any time and opt out by following the instructions in this section. Note that, due to the nature of the Services, a User may have to login to her/his account or provide the email and/or other identifying value that is associated with the Personal Information in order for us to complete the request.
  2. Email unsubscribe – An “Unsubscribe” button will be provided in each email communications sent by us so that the User can opt-out. However, we may continue to send transaction-related emails regarding products or Services this same User has requested in response to such request. We may also need to send certain communications regarding our programs and Services and Users will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Use or this Privacy Statement.
  3. Opt-out of cookies and ads. Users may stop or restrict the placement of technologies on their devices or remove them by adjusting their preferences as their browser or device permits, or for this Site using the Cookies Settings link at the bottom of the webpage. Such Cookie Setting will be present whenever such technology devices are in use on the Site or in other Services. The online advertising industry also provides websites from which Users may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. Users can access these and learn more about targeted advertising and consumer choice and privacy, at networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, Users can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices Users may use the device’s platform controls in your settings to exercise choice.  Please note a User must separately opt out in each browser and on each device.
  4. Do Not Track – Do Not Track (“DNT”) is a privacy preference that Users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. CTMi does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device. For information about “do-not-track”, visit http://www.allaboutdnt.org.
  5. Access, correct, amend or delete Personal Information – Users may seek confirmation regarding whether we are processing Personal Information about them, request access to Personal Information, and ask that we correct, amend or delete their Personal Information where it is inaccurate or has been processed in violation of applicable data protection laws. You have the right to control or change certain uses and disclosures of your Personal Information, as set out in this Privacy Statement. Where otherwise permitted by applicable law, a User may log into her/his account or email dataadmin@ctminteractive.com with the word “Privacy” in the subject line, to request access to, receive, restrict processing, seek rectification or request erasure of Personal Information held about you by us. Such requests will be processed in accordance with local laws. Although we make good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide the User with an explanation of why that determination has been made and a contact point for any further inquiries. To protect the User’s privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Note this important notice in regard to “Customer Data.”  As a data processor for our business customers, we process data that may include Personal Information of our business customer’s end user clients (“Customer Data”). We will not review, share, distribute or reference any such Customer Data except as provided in the Agreements between us and our business customers, or as may be required by law. If Personal Information pertaining to an individual has been submitted to us by our business customer and such individual wishes to exercise any rights, she/he may have to access, correct, amend or delete such data, please inquire with the relevant customer directly. Because CTMi personnel have limited ability to access Customer Data, if an individual wishes to make a request directly to us, she or she should provide the name of the relevant CTMi customer. We will refer such request to that customer and will support them as needed in responding to the request.

Notice to EU residents – If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.

CA residents. Please refer to the information below.

  1. Notice to California consumers – In addition to the rights set out in this privacy policy, California law, including the California Consumer Privacy Act of 2018 (the “CCPA”), provides for additional rights to California consumers. Those rights as a California consumer are summarized below.
  2. California consumer have the right to request additional information about their personal information, including the categories and specific pieces of personal information we have collected about them, the source of such personal information, the purpose for such collection, and information about how their personal information is shared with third parties.
  3. We will not discriminate against any individual in the event that she/he exercises any of these rights as a consumer under the CCPA. If an individual wishes to submit a request under the CCPA, please refer to the ‘Contact us’ section of this privacy policy. If contact is via email, please indicate “California” in the subject line.

Redress, compliance and accountability – If after reviewing this Privacy Policy, any User would like to submit a request or has any questions or privacy concerns, then she/he should contact:  dataadmin@ctminteractive.com .  The Company will address your concerns and attempt to resolve any privacy issues in a timely manner.

An EU, Swiss or UK citizen believing that CTMi is not abiding by the terms of this Privacy Statement, that individual should contact us at the contact at dataadmin@ctminteractive.com, or via information provided below. If any request remains unresolved, individuals may contact the national data protection authority for their EU Member State, Switzerland or United Kingdom.

 

THIRD PARTY SITES

Please note that our Services may contain links to other websites or digital properties for your convenience and information. We do not control third party websites, digital properties or their privacy practices, which may differ from those set out in this Privacy Statement. We do not endorse or make any representations about third party websites or digital properties. Any Personal Information that a User might choose to give to unrelated third party is not covered by this Privacy Policy. We encourage Users to review the privacy policy of any company, website or digital property before submitting Personal Information. Some third parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s privacy policy, not this Privacy Statement.

CHANGES TO THIS PRIVACY STATEMENT

We may update this Privacy Statement from time to time as it deems necessary in our sole discretion. We will provide notification of any material changes to this Privacy Statement through our Sites or as otherwise required by applicable law. We encourage Users to review this Privacy Statement periodically to be informed regarding how We are using and protecting Personal Information and to be aware of any policy changes. Each User’s continued relationship with us after the posting or notice of any amended Privacy Statement shall constitute her/his agreement to be bound by any such changes. Any changes to this Privacy Statement take effect immediately after being posted or otherwise provided by us.

CONTACT US

For any questions about our privacy practices or this Privacy Statement, and/or to submit a request to exercise an individual’s rights, please contact us at:

CTM Interactive

Mail Address:    17912 Holderreith Road, Tomball, Texas 77377 USA

Email:               dataadmin@ctminteractive.com

CONTACT US