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1. Home
2. Privacy
PRIVACY AND COOKIES
GLOBAL CSC PRIVACY NOTICE
AT CSC® WE VALUE YOUR RELATIONSHIP AND RESPECT YOUR TRUST.
In this Privacy Notice, “CSC group”, "CSC", "we", "us", "our" means (as the
context dictates) the Corporation Service Company, a corporation incorporated in
the State of Delaware, under registration number 0101330 and/or the relevant CSC
group company (which includes the Intertrust Group companies) that delivers
services to you or otherwise handles your personal data as a controller. Further
details of all CSC group companies are set out in Section 18 of this policy.
We are a global business headquartered in the U.S. and our group companies
deliver diverse services in accordance with local laws.
If there is any conflict between the policies in this Privacy Notice and the
Data Protection Legislation (as defined below), the Data Protection Legislation
shall govern in respect of EU data subjects.
CSC is subject to the investigatory and enforcement authority of the United
States Federal Trade Commission. Local group companies are supervised by, and
accountable to, local data protection authorities (see more below).
About this Privacy Notice
In this Privacy Notice, references to "you" and "your" are references to a user
of our websites https://www.cscglobal.com/cscglobal/home/ and/or
https://www.intertrustgroup.com/ or our apps, an individual who submits a query
to or does business with CSC in their personal or professional capacity, applies
for a job via cscglobal.com/careers or other individuals whose Personal Data we
obtain or control in the course of carrying on our commercial activities. Those
individuals could be clients or prospective clients or their representatives,
agents or appointees, or employees, directors, officers, or representatives of
another organization with which we have a business or other relationship.
We are committed to protecting and respecting your privacy and handling your
information in an open and transparent manner. This Privacy Notice explains how
we handle and protect your personal data, how we gather this data, and how we
manage this data to serve you. This Privacy Notice may be supplemented by local
service line privacy policies or notices we provide from time to time alongside
our business terms. We may change this Privacy Notice from time to time as the
need arises to accurately reflect how we gather and manage your personal data.
All changes to this Privacy Notice will be effective upon posting to the
websites https://www.cscglobal.com/cscglobal/home/ and / or
https://www.intertrustgroup.com/legal/data-protection-and-privacy/ without any
other notice to you, unless an alternative notice is required under law. This
Privacy Notice is effective as of December 1, 2014 and was last updated on 1
March, 2024.
In this Privacy Notice the term "Data Protection Legislation" means the EU
General Data Protection Regulation 2016/679 (“GDPR”); together with (where the
context dictates) all other applicable legislation relating to privacy or data
protection including the GDPR as incorporated into UK law by the UK European
Union (Withdrawal) Act 2018 (“UK GDPR”), the Personal Data Protection Act (No.
26 of 2012) of Singapore (“PDPA”), the Personal Information Protection Law of
the People's Republic of China (“PIPL”), and Personal Data (Privacy) Ordinance
of Hong Kong (“PDPO”).
This Privacy Notice also describes, in section 16, our information practices and
the rights afforded to California residents under the California Consumer
Privacy Act (Civ.Code 1798.100-.199) (“CCPA”).
1. WHAT IS PERSONAL DATA?
"Personal data," where used in this Privacy Notice, shall mean any information
or set of information that identifies an individual, or could be used by or on
behalf of CSC to identify an individual, and shall include any data about an
identified or identifiable individual that are within the scope of Data
Protection Legislation and recorded in any form. Personal data does not include
information which is anonymized. Personal information about California residents
(“CCPA Personal Information”) is defined in section 16.
We may refer to your personal data as your information and may sometimes
collectively refer to handling, collecting, protecting and storing your personal
data as "processing" such personal data.
2. SCOPE OF THIS PRIVACY NOTICE
Except as otherwise provided herein, this Privacy Notice applies to personal
data submitted to or collected by us for our service providing, through this
website, CSC's various service applications and otherwise in connection with the
carrying out of our business save that it does not apply when CSC act on behalf
of its clients as processors. This Privacy Notice may be supplemented by service
or group member specific privacy policies and notices provided alongside our
business terms from time to time.
3. WHAT INFORMATION WE COLLECT, AND WHY
CSC collects, uses, stores and transfers different kinds of personally
identifiable information which can be grouped together as follows:
* Identity Data: includes first name, last name, marital status, business or
other title or role (employment status), date of birth, nationality, gender,
source of wealth, and copies of identity documents (such as passport,
national ID card, driver’s license, employee identification).
* Contact Data: includes home or work address county details, email address and
telephone numbers.
* Purchase Data: includes payment information, purchase history, and your
reviews and opinions about our products and services.
* Marketing and Communications Data: includes your preferences in receiving
marketing from CSC, your communication preferences, interests and engagement
information.
* Website and App Data: includes your IP address, your browser type and
language and information about your visit to our website, including log
files, the full Uniform Resource Locators (URL) clickstream to, through and
from our site (including date and time), length of visits to certain pages,
page interaction information (such as scrolling, clicks, and mouse-overs) and
methods used to browse away from the page.
* Device Data: includes information about the device which you use to access
the website and our apps (as set out in more detail in section 4.2 below).
* Compliance Data: includes, if legally required to collect such information,
Know Your Customer / Anti Money Laundering information from relevant
individuals, such as source of wealth, tax residency, details of
shareholdings and other assets which are legally or beneficially owned by
you, and details of people and organizations which may be connected to you.
* Contract Information: includes information necessarily processed in a project
or contractual relationship with CSC or voluntarily provided by a relevant
individual such as personal data relating to orders placed, payments made,
requests, and project milestones.
Some CSC services may require additional information which we will inform you of
when we request such information.
4. HOW WE COLLECT YOUR INFORMATION
4.1 INFORMATION PROVIDED BY YOU
CSC may collect or obtain personal data directly from you (for example by
completing a form related to a service request or to a KYC procedure).
If you use one of our websites or apps, its various applications, or during our
exchanges or otherwise in connection with our services, you may be required to
provide Identity Data, Contact Data, Marketing and Communications Data, Contract
Information, Compliance Data, as well as account number, service and product
interest information, and intended use of services or products. In addition, you
may choose to provide additional information relating to yourself or your
companies to take advantage of different services available on our websites,
apps or elsewhere.
We generally do not require you to provide sensitive personal data, such as that
which reveals race, ethnic origin, political opinions, religious or
philosophical beliefs, trade union membership, or information that concerns
health, biometrics or sexual orientation or life. To the extent you make
sensitive personal data available to CSC, we would usually obtain your consent
to CSC processing such personal data in accordance with this Privacy Notice save
where any other legal grounds applied.
4.2. INFORMATION WE COLLECT ABOUT YOU
CSC may also collect or obtain personal data indirectly because other people
give that Personal Data to us (for example your employer or adviser) or because
it is publicly available.
We also periodically gather certain information about the device of website and
app users with your consent where required under law where required or
automatically and store it in log files. This information includes browser type,
internet service provider, referring/exit pages, operating system, date/time
stamp, and click-stream data.
We collect information which your device transmits to connect to our websites
and apps in order to identify the device which you use to log in to the
restricted parts of our websites and apps, and to identify logins from new
devices. This technique is known as "device fingerprinting" and we use it to
keep your account and the services we provide to you or your employer secure.
The data which we collect in this manner is comprised of information about your
device display, your operating system, and your browser, namely the language
settings of your browser and system, the fonts used by your system, the
dimensions of your display, and the geolocation and time-zone of your device.
We also use "cookies" and similar technology to access or store information on
your devices to help us make our sites – and the way you use it – better, as
well as to provide you with online advertising which is relevant to you. Cookies
mean that a website will remember you. They're small text files that sites
transfer to your device (computer, phone, or tablet etc.). They improve website
use and speed – for example by automatically filling in your name and address in
text fields. There are more details in the section on our cookies policy below.
4.3. CHILDREN'S INFORMATION
We do not knowingly collect information from children under the age of 18 and we
do not target our websites, apps or services to children under 18. Where CSC
collects and processes personal data of minors as defined under applicable laws
in the course of its service providing, the disclosing party hereby confirms
that the consent of the minor’s guardian or a person with parental
responsibility has been provided.
5. HOW WE USE YOUR INFORMATION
We may use the personal data we collect:
* to provide you with information, goods, or services which you have requested;
* to contact you in connection with support-related activities;
* for planning, performing and managing our contractual relationships;
* for compliance with statutory and regulatory obligations of CSC or internal
policy requirements and the order of a competent court, as well as (but not
limited to) accounting, commercial communications, know-your-customer and
anti-money laundering requirements, general management of the services or
customer relationship purposes;
* to contact you in the event that we have announcements regarding our
services, our websites, the applications within our websites or our apps;
* for general research and development of our business;
* to fulfill any other purpose for which you provided it;
* for billing and collection purposes;
* to analyze the use of our services and websites;
* to secure the services which we provide to you or your employer;
* in any other way we may describe when you provide the data;
* in connection with services CSC receive from professional advisors, such as
lawyers and consultants or other service providers either to execute CSC’s
contractual obligations towards you or CSC’s clients or our business
purposes;
* to solve disputes, enforce our contractual agreements and to establish,
exercise or defend legal claims; and/ or
* for any other purpose with your consent.
We do not conduct automated decision-making including profiling.
We may also use your personal data to contact you about our own goods and
services that may be of interest to you in line with your preferences and Data
Protection Legislation.
If you do not want us to use your information in this way, or any of the ways
described above, please contact us using the details below. You have certain
rights, set out in sections 9 and 14 below.
6. LEGAL GROUNDS FOR USING YOUR PERSONAL INFORMATION
The law permits us to process your personal data in the way that it does because
the processing is:
* necessary for the purposes of the legitimate interests that we pursue, which
are to run and administer our business, to ensure the security our services,
to discharge our legal obligations to store and disclose information where
necessary and to evaluate, develop and improve our services and market new
and improved services; and/or
* necessary for the performance of our contract to provide you with the
services you have ordered; and/or
* necessary in order to comply with a legal obligation to which we are subject.
7. DISCLOSURE AND TRANSFER OF YOUR INFORMATION
In some instances, we may be asked to disclose certain personal data pursuant to
a court order, subpoena, search warrant, or law enforcement request. We may also
disclose your information in order to enforce our terms of use or to protect the
rights, property, or the personal safety of (in each case) us, our staff,
customers, and others. In addition, we may disclose your information in order to
permit us to pursue available remedies or limit the damages that we may sustain,
to respond to an emergency, or in the event that we sell (or propose to sell)
any property, business or assets, we may disclose your information to the
prospective buyer under a confidentiality agreement, in which case we shall
notify you as may be required pursuant to applicable legislation. Please note
that CSC may be required to release an individual's personal information in
response to lawful requests by public authorities, including to meet national
security and law enforcement requirements.
7.1. CSC AFFILIATES AND SERVICE PROVIDERS
Subject to all applicable laws, each relevant CSC group company we may disclose
your personal data on a need-to-know basis for the purposes described in this
Privacy Notice to any other member of our company group to include those set out
in Section 18 below.
Some CSC group companies may have their own websites and apps with their own
unique privacy policies, tailored to the services they provide. We encourage you
to read those privacy policies carefully when you visit those affiliated sites
or receive their services.
From time to time, we may engage our affiliated entities or other carefully
selected third parties to provide services on our behalf, such as legal
advisors, accounting firms and information technology providers in particular to
collect, process, and use your personal data as required to provide services to
you. We may disclose your information to such service providers in compliance
with applicable data protection law, and provided that they agree to use your
information only for the purposes of providing the services. We will not
disclose your personal data to a third party without complying with Data
Protection Legislation requirements including those relating to notice and
consent unless otherwise required by law.
When using third-party vendors or agents to which CSC intends to transfer
personal data, CSC shall perform adequate due diligence to help ensure the
security of such information, including ensuring that such third party has
entered into a written agreement with CSC requiring the third party to provide
at least the same level of privacy protection as is required by the Data
Protection Legislation. CSC shall continue to be liable under the Data
Protection Legislation if third parties to which CSC has transferred personal
data for processing on CSC's behalf do so in a manner that is inconsistent with
the Data Protection Legislation. However, CSC will not be liable if it can prove
that it is not responsible for the event that caused damage.
7.2. TRANSFERS OVERSEAS
The personal data we receive will be held on our computers and systems in the
United States and the European Economic Area (EEA) and may be accessed by or
given to our staff, one of our affiliates or carefully selected suppliers
working in the United States or otherwise outside the EEA.
Where recipients are outside the EEA, we ensure that the recipient provides an
adequate level of protection for your personal data or the transfer is otherwise
permitted under applicable Data Protection Legislation, by methods including
using standard contractual clauses, or by relying on a relevant adequacy
decision by the European Commission or any other competent body. We undertake
risk assessments for each type of transfer and will apply additional safeguards
where the results of these assessments recommend such action.
Where you are a controller that shares personal data with us where we are also a
controller, Module 1 of the standard contractual clauses contained in the annex
to Commission Implementing Decision (EU) 2021/914 of 4 June 2021 and, where
relevant, the International Data Transfer Addendum to the EU Standard
Contractual Clauses issued by the ICO under s119A(1) of the Data Protection Act
2018, version B1.0, in force 21 March 2022, both as may be amended from time to
time, shall be deemed to be incorporated into any arrangement in place between
us.
8. JOB APPLICANTS
This section describes how the CSC group handles and protects the personal
information of job applicants, i.e. through the online CSC careers website.
CSC processes the following types of personal data of job applicants:
* Name, address, email address, telephone number and other contact information;
* Date and place of birth;
* Nationality;
* Immigration, right-to-work and (tax) residence status;
* Job-related information such as years of experience and work records;
* Educational and training information;
* Skills and competencies;
* Name and contact details of references (please note that if you provide us
with contact details of reference it is your responsibility to obtain
consent from that individual before sending this information to us).
* Any other personal information you choose to submit to us in connection
with your application.
CSC use the personal data you provide for the purpose of carrying out our
recruitment activities. The personal data will, inter alia, be used to assess
qualifications, to verify the information and for communication purposes.
9. OPTING OUT
Where required by Data Protection Legislation, you will be given a choice when
you provide us with your personal information to opt into certain uses we may
intend to make of that information, such as sending you our newsletter,
information or offers containing updated information about us, our goods,
services, and promotions. You may also be asked if you would like to receive
marketing from third-party organizations. You will be able to indicate your
consent to each specific proposed use by checking the relevant box to opt in. We
will not send you direct marketing or pass your details to third parties for the
purpose of them sending you direct marketing, without your consent.
You also have the option of "unsubscribing" from our mailing list for
newsletters, alerts, and updates at any time, thereby disabling any further such
e-mail communication from being sent to you.
Details of how to unsubscribe will be included on each electronic mailing we
send you. Alternatively, just send an email to onlinemarketing@cscglobal.com
with "URGENT – UNSUBSCRIBE REQUEST" in the subject line and the email address
that you wish to be removed from the email.
We will action any opt out request from you without delay, and in any event
within one month.
10. WEBSITE LINKS TO OTHER SITES
For your convenience, our websites and apps may contain links to websites that
are owned or operated by third parties not affiliated with CSC. We can make no
promises or guarantees regarding personal data collection or privacy practices
on websites that are not owned or operated by CSC. We strongly suggest that you
review each such third parties' privacy policies before providing any personal
data to them. These other sites may send their own cookies to users, collect
data, or solicit personal data. You should contact these entities directly if
you have any questions about their use of the information that they collect.
11. STEPS WE TAKE TO ENSURE YOUR PRIVACY
The security of your personal data is important to us. We use generally
accepted, industry standard tools and techniques to protect your personal data
against unauthorized disclosure. However, no method of transmission over the
internet, or method of electronic storage, is 100% secure. Therefore, while we
strive to use commercially reasonable means to protect your personal
information, we cannot guarantee its absolute security.
11.1. PERIMETER SECURITY
We use firewalls to secure the perimeter of our information network and monitor
our systems regularly.
11.2. DATA SECURITY
An authentication and authorization mechanism based on (i) user identification
(ID) and password, and (ii) device identification, is used to restrict access to
information on CSC's websites and apps. Each authenticated user only has access
to the information that he or she is authorized to use. We use physical,
administrative, and technical procedures to limit access to personal
information.
We identify devices through the use of device fingerprinting. A description of
the data which we collect for this purpose can be found in section 4.2 of this
policy.
11.3. TRANSACTION SECURITY
All personal data exchanged between our servers and your web browser is
encrypted using Secure Sockets Layer.
12. SOCIAL ENGINEERING (OUR EMPLOYEES)
All of our employees are made aware of and reminded of our Confidentiality of
Client Information Policy regularly and must acknowledge that they have received
and read it.
13. STEPS YOU CAN TAKE TO ENSURE YOUR PRIVACY
Remember that you play a vital role in ensuring the security of your information
on our websites and the applications within. Here are a few steps you can take
to maintain the privacy of your information:
13.1. MANAGING YOUR PERSONAL DATA
Registration for access to our websites requires that you provide personal data
(including name, company name, company address, including city, state, country,
ZIP code, company email address, and company phone number). It is your
responsibility to make sure this information is accurate and current. If your
personal data changes, you should update it by logging into the sites and
visiting the account detail pages or by contacting us using the contact details
above. If you require assistance with updating this information, you may contact
our staff twenty-four hours a day, seven days a week, at +1 (302) 636-5400 X
68952 or your local office.
We will process all information update requests in a timely manner.
13.2. SAFEGUARD PASSWORDS
You should take the necessary precautions to safeguard your user ID and password
to prevent unauthorized access to your personal data stored on our websites and
the applications within. If you feel that your user ID and password have been
compromised, access our website and reset your password or contact our Technical
Support staff immediately twenty-four hours a day, seven days a week, at: +1
(302) 636-5400 X 68952 or your local office.
Your password will be reset and emailed to you at the address maintained on
record.
13.3. ERASE TEMPORARY FILES
Any information you entered during your session may be temporarily stored in the
memory storage area of your computer. Closing the browser will erase this
information if you have your browser set to automatically erase temporary files
when it is closed.
13.4. USE OF A FIREWALL
Consider using a firewall to help prevent unauthorized access to your network or
personal computer, especially if you are using a DSL or cable modem to access
the internet.
14. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
At any time, you have the right:
* to be informed about the processing of your personal data (i.e. for what
purposes, what types of personal data, to what recipients it is disclosed,
storage periods, any third-party sources from it was obtained, data transfers
outside the EEA and UK, confirmation of whether we undertake automated
decision-making, including profiling, and the logic, significance, and
envisaged consequences);
* to request access to or a copy of any personal data which we hold about you;
* to rectification of your personal data, if you consider that it is
inaccurate;
* to ask us to delete your personal data, if you consider that we do not have
the right to hold it;
* to withdraw consent to our processing of your personal data (to the extent
such processing is based on previously obtained consent);
* to ask us to stop or start sending you marketing messages (e.g. our
newsletter) at any time by using the below contact details;
* to restrict processing of your personal data;
* to data portability (moving some of your personal data elsewhere) in certain
circumstances;
* to object to your personal data being processed in certain circumstances; and
* to not to be subject to a decision based on automated processing and to have
safeguards put in place if you are being profiled based on your personal
data.
In addition, you have the right to make a complaint to your local supervisory
authority with respect to the way CSC is processing your personal data or the
way CSC handles your rights.
Individuals wishing to access their personal information can do so in writing or
may request it orally twenty-four hours a day, seven days a week, by contacting
CSC's Data Protection Officer directly at DPO@cscglobal.com or calling +1 (302)
636-5400 X 68952. CSC will endeavor to respond within a reasonable period and in
any event within one month in compliance with Data Protection Legislation. We
will comply with our legal obligations as regards your rights as a data subject.
If you wish to exercise any of the other rights detailed above please contact us
at DPO@cscglobal.com.
We will correct any incorrect or incomplete information and will stop processing
your personal data, or erase it, where there is no legal reason for us to
continue to hold or use that information.
We aim to ensure that the information we hold about you is accurate at all
times. To assist us in ensuring that your information is up to date, do let us
know if any of your personal details change.
If you wish to exercise any of the other rights detailed above please contact us
at DPO@cscglobal.com or if you require additional assistance you may contact our
staff twenty-four hours a day, seven days a week, at: Phone: +1 (302) 636-5400 X
69852 or your local office.
15. SUSPECTED OR KNOWN SECURITY EVENTS
CSC users who report suspected or known security events that may jeopardize the
confidentiality, integrity, or availability of CSC information, information
systems, and/or information processing facilities shall not be retaliated
against, intimidated, or otherwise prevented or harassed for making such a
report.
16. HOW LONG WE KEEP YOUR INFORMATION
We will only keep the information we collect about you for as long as required
for the purposes set out above or as required to comply with any legal or
contractual obligation to which we are subject, exercise or defense of legal
claims, and where we have a legitimate interest for doing so. This will involve
us regularly reviewing our purposes or files to check that information is
accurate, up-to-date and still required.
We may send you direct marketing communications and retain your contact
information as necessary for this purpose, (provided that we are entitled to
send you these, and for as long as you do not unsubscribe from receiving the
same from us.
17. CALIFORNIA CONSUMER PRIVACY ACT RIGHTS
The CCPA provides California residents with rights with respect to CCPA Personal
Information. “CCPA Personal Information” means information that identifies,
relates to, describes, is capable of being associated with, or could reasonably
be linked, directly or indirectly, with a particular California resident or
household. The information practices described in this section include CCPA
Personal Information we receive either online or off-line in any format.
17.1. AS OF JANUARY 1, 2020, VERIFIED CALIFORNIA RESIDENTS WILL HAVE THE RIGHT:
* to request and receive disclosure of our CCPA Personal Information collection
practices during the prior 12 months, including the categories of CCPA
Personal Information we collect, the categories of sources of such
information, our business purpose for collecting o sharing such information,
and the categories of third parties with whom we share such information.
* to request and receive a copy of the CCPA Personal Information we have
collected about them during the prior 12 months.
* to request and receive disclosure of our information sale practices during
the prior 12 months, including a list of the categories of CCPA Personal
Information disclosed for monetary or other valuable consideration and the
categories of third-party recipients and a list of the categories of CCPA
Personal Information that we disclosed for a business purpose and the
categories of third-party recipients.
* to request that we not sell CCPA Personal Information about them and
* to request that we delete (and direct our service providers to delete) their
CCPA Personal Information subject to certain exceptions.
We will not discriminate against you as a result of your exercise of any of
these rights.
17.2. MAKING REQUESTS
In order to make a request for disclosure California residents may contact us at
DPO@cscglobal.com or if you require additional assistance you may contact our
Customer Service staff from 8:00 a.m. to 8:00 p.m. U.S. Eastern Time, Monday
through Friday, at: Phone: +1 (800) 927-9800. We will ask you for information
that allows us to reasonably verify your identity (that you are the person about
whom we collected CCPA Personal Information) and will use that information only
for that purpose. We cannot respond to your request or provide you with
disclosures if we cannot verify your identity and confirm that the CCPA Personal
Information we hold relates to you.
You may make a request up to twice within a 12-month period. We will endeavor to
respond within forty-five days of receipt of your request, but if we require
more time (up to an additional forty-five days) we will notify you of our need
for additional time.
For requests for a copy of the personal information we have collected during the
12 months prior to your request we will endeavor to provide the information in a
format that is readily useable, including by mailing you a paper copy or
providing an electronic copy to your registered account, if you have registered
an account with us.
If you are over the age of 16 and would like to instruct us not to sell your
personal information, please visit our Do-Not-Sell web page here. We do not sell
personal information of individuals we actually know are less than 16 years of
age. Once we receive your Do-Not-Sell request we will wait at least 12 months
before asking you to reauthorize personal information sales.
17.3. INFORMATION COLLECTION, USE AND DISCLOSURE.
The information practices described below include information collected from our
site visitors, registered users, employees, vendors, suppliers, and any other
person that interacts with us either online or offline. Not all types of
information are collected about all people interacting with us. For instance, we
may collect different information from applicants for employment than we do from
our customers.
17.3.1. Our Collection of CCPA Personal Information during the past 12 months.
We may have collected the following categories of information directly from you:
information protected against security breaches (such as your name and financial
account, driver’s license, social security number, user name and password,
health/medical information), protected classification information (like race,
gender, ethnicity, etc.), commercial information, Internet/electronic activity,
geolocation, audio/video data, professional or employment related information,
education information, and inferences from the foregoing. We may have collected
the following categories of information from third parties : information
protected against security breaches (such as your name and financial account,
driver’s license, social security number, user name and password, health/medical
information), protected classification information (like race, gender,
ethnicity, etc.), commercial information, Internet/electronic activity,
geolocation, audio/video data, professional or employment related information,
education information, and inferences from the foregoing. We may have collected
the following categories of information from our own observations : information
protected against security breaches (such as your name and financial account,
driver’s license, social security number, user name and password, health/medical
information), protected classification information (like race, gender,
ethnicity, etc.), commercial information, Internet/electronic activity,
geolocation, audio/video data, professional or employment related information,
education information, and inferences from the foregoing.
17.3.2. Our use and disclosure of CCPA Personal Information during the past 12
months.
We have used the collected information for the purposes set forth in Section 5
above.
We may have disclosed the following categories of information in order to
conduct our business operations and for our business purposes (for instance
providing services to you, completing transactions, managing employees and
vendors, security, quality control, marketing and analytics): information
protected against security breaches, protected classification information,
commercial information, Internet/electronic activity, geolocation, audio/video
data, professional or employment related information, education information, and
inferences from the foregoing.
We do not provide your data to third parties in exchange for monetary
consideration but during the past 12 months we may have disclosed data to
certain third parties that provide us with services such as data analysis and
security information, which may fall under the definition of “consideration” and
therefore be deemed a “sale” under the CCPA. We have disclosed the following
categories of information to third parties for valuable (but not monetary)
consideration: information protected against security breaches, protected
classification information, commercial information, Internet/electronic
activity, geolocation, audio/video data, professional or employment related
information, education information, and inferences from the foregoing.
18. CONTACT DETAILS AND INDEPENDENT RECOURSE MECHANISM
Any questions, complaints, access requests, and any other issues arising under
the Data Protection Legislation should be directed first to CSC's Data
Protection Officer at DPO@cscglobal.com.
CSC commits to resolve complaints about your privacy and our collection or use
of your personal information. European Union or Swiss individuals with inquiries
or complaints regarding this Privacy Notice should first contact CSC at
DPO@cscglobal.com.
If your complaint is not satisfactorily addressed by CSC, you may have your
complaint considered by an independent recourse mechanism: for EU/EEA Data
Subjects, the data protection authority (“DPA”) in your jurisdiction (for
example in the UK the Information Commissioner's Office (“ICO”), and for Swiss
Data Subjects, the Swiss Federal Data Protection and Information Commissioner
(“FDPIC”).
To do so, you should contact the state or national DPA in your jurisdiction
(e.g. the ICO in the UK). CSC agrees to cooperate with the relevant national
DPAs and to comply with the decisions of the DPA Panel and the FDPIC.
Should your complaint remain fully or partially unresolved after a review by CSC
and the relevant DPA, you may be able to, under certain conditions commence
legal proceedings in your local jurisdiction or possibly, under certain
conditions, individuals may invoke binding arbitration.
19. COOKIE POLICY
CSC is committed to transparency when it comes to the technologies we use, and
we've outlined below how we use cookies (and similar technologies) when you
visit our website and apps. CSC is committed to transparency when it comes to
the technologies we use, and we've outlined below how we use cookies when you
visit our website and apps.
19.1 WHAT ARE COOKIES (AND SIMILAR TECHNOLOGIES)?
Cookies
Cookies are small pieces of code issued to your device when you visit a website
or app, which store and sometimes access or track information about your use of
our site or our app. We use cookies to elevate your user experience and the
quality of our site and service. When you enter our sites, our web servers send
a cookie to your device, which allows us to recognize your device.
When you access our website outside of Europe or the UK, our system will
automatically issue cookies when you log on to our website (unless you have set
your browser to reject them).
If visiting a CSC website from Europe or the UK, we display a banner to explain
how we use cookies on our homepage, so that you can consent to our placement of
cookies on your browser. The banner appears until you click "I agree." We place
a persistent cookie on your browser to log your consent, if appropriate.
You are free to refuse consent but please be aware that restricting cookies will
impact your user experience and may prevent you from using part of our website.
Cookies can be removed from your browser in two ways: automatically (when they
expire), or when you manually delete them. We've included more details below to
help you understand what kinds of cookies we use and how you can manage them.
Email tracking
Our e-communications platforms include technology and code which works by
incorporating and sending tracking pixels and/or images within certain email
communications and updates we issue - including those sent in accordance with
section 9 (above).
The technology automatically returns information to our platforms when an email
is opened – so we can confirm if the email was opened or not. The technology
also allows e-commerce platforms to record the time and date of opening, how
many times it is opened, the general location when opening, operating systems or
the device used, user IP address, any click through using hyperlinks in the
communications, whether attachments are opened, further browsing information and
whether the communication is forwarded.
Technologies similar to cookies: Device fingerprinting
In addition to cookies, we also use "device fingerprinting". This entails
collecting information which you affirmatively provide (such as a mobile phone
number associated with your device) or your device automatically transmits to
connect to our website or mobile apps that builds a unique image of your device.
Unlike cookies, this does not involve issuing pieces of code to your device.
However, similar to cookies, it enables us to recognize your device.
We only use device fingerprinting to keep your account and the services we
provide to you or your employer secure. We consider this to be strictly
necessary for providing our services therefore we do not require consent to use
device fingerprinting.
19.2 WHY DOES CSC USE COOKIES, EMAIL TRACKING AND DEVICE FINGERPRINTING?
CSC's primary reason for using cookies is to make our website and apps work more
effectively.
We use cookies to track the performance of our website and apps so that we can
improve them, and enable the selection and delivery of online advertising, which
is relevant to you.
We use email tracking technology and pixels to assess whether an email has been
opened or otherwise. This is for the purpose of assessing engagement with our
communications, tailoring our communications, service and legal updates,
newsletters, marketing and assessing their value and effectiveness. When used,
this technology helps us to consider whether, when and how we should issue
further communications or whether they should stop sending them generally to
specific recipients.
As explained above, we only use device fingerprinting to keep our services
secure.
19.3 WHAT KINDS OF COOKIES DOES CSC USE AND WHY?
Our websites and apps use the following cookies:
* Strictly necessary cookies. These are cookies that are required for the
operation of our site and the apps. They include, for example, cookies that
enable you to log into secure areas of our site and apps. We do not require
your consent to place these cookies. Nevertheless, you may be able to block
these cookies yourself on your device/ browser, but restricting these cookies
is likely to mean that our site will not work as you would expect and certain
functionality may be inoperable.
Our use of device fingerprinting also falls under this category.
* Non-essential cookies. These include the following:
* Analytical/performance cookies. These allow us to recognise and count the
number of visitors and to see how visitors move around our site and apps
when they are using them. This helps us to improve the way our site works,
for example, by ensuring that users are finding what they are looking for
easily. We use cookies to compile visitor statistics such as how many
people have visited our site and apps, how they reached our site, what type
of technology they are using (e.g. Mac or Windows, which helps to identify
when our site isn't working as it should for particular technologies), how
long they spend on the site and apps, what page they look at etc. This
helps us to continuously improve our website and apps.
* Functionality cookies. These are used to recognise you when you return to
our site or apps. This enables us to personalise our content for you, greet
you by name and remember your preferences (for example, your choice of
language or region).
* Advertising cookies. CSC uses remarketing. Placing a remarketing tag on our
website can help us reach visitors who have previously visited our website
as they visit other sites on the Google Display Network™ service or search
on Google®. Using remarketing, these visitors will be shown messages
tailored to which sections of our site they visited. The remarketing tag
uses third-party cookies from the Google Display Network. Visitors can
opt-out of Google's use of cookies by visiting Google Ads settings.
Remarketing tags are not used on CSC's microsites such as cscglobal.co.uk,
cscglobal.de, cscglobal.es and cscglobal.fr.
These cookies may be:
* Session cookies: These temporary cookies expire and are automatically erased
whenever you close your browser. We use session cookies to grant our
customers access to content and to enable commenting.
* Persistent cookies: These usually have an expiration date in the distant
future and remain in your browser until they expire or you manually delete
them. Persistent cookies may be used for a variety of purposes including
remembering our users' preferences and choices when using our site or to
target advertising. First- and third-party cookies: Whether a cookie is
"first" or "third" party refers to the website or domain placing the cookie.
In basic terms, first-party cookies are set by a website visited by the
user—the website displayed in the URL window. Third-party cookies are cookies
that are set by a domain, such as google.com, other than the one being
visited by the user. If a user visits a website and a separate company sets a
cookie through that website, this would be a third-party cookie.
19.4 WHAT OTHER COOKIES MIGHT YOU ENCOUNTER ON A CSC WEBSITE?
We may also use third-party cookies on the site. In keeping with our policies,
these session or persistent cookies are set only by trusted partners of CSC.
These cookies may collect information about your online activities across
websites and over time.
The third parties who set cookies through our site include LinkedIn, Maxmind,
Youtube, Facebook and Doubleclick.
The third-party cookies we may use on our website and apps may track site
performance and usage, monitor chat sessions or a users' location, or compile
reports that help us improve the site and apps. When you access our website, in
certain jurisdictions, as required by law, you will receive a clear notice
advising you that we intend to use cookies and that you must click an "I accept"
box in order for cookies to be placed.
If you prefer not to receive cookies through our website, you can set your
browser to either reject all cookies (see below), to allow only "trusted"
websites to set them, or to accept only those cookies from those sites you
currently use. If you access our website in Europe, you can refuse to click the
"I accept" box or click the "I disagree" box when you are presented with a
cookie notice on our homepage.
When you access our website outside of Europe, our system will automatically
issue cookies when you log on to our website and apps (unless you have set your
browser to reject them).
19.5 COOKIES WE DO NOT USE
We do not use flash cookies (sometimes known as local shared objects or LSOs).
19.6 DOES CSC USE COOKIES TO SELL CUSTOMER INFORMATION?
We do not use cookies to provide your data to third parties in exchange for
monetary consideration, but we may receive other consideration for allowing
third parties to access cookies.
19.7 WILL THE SITE WORK IF YOU DISABLE COOKIES?
You can browse our site with cookies disabled, though some interactions may not
work properly.
19.8 EU COOKIE LAW
If visiting a CSC website from Europe, we display a banner to explain how we use
cookies on our homepage, so that you can consent to our placement of cookies on
your browser. The banner appears until you click "I agree" or "I disagree." We
place a persistent cookie on your browser to log your consent, if appropriate.
Please be aware that our microsites will not display this banner, as we do not
utilize cookies on any of our microsites.
19.9 MANAGE YOUR COOKIES
There are several ways you can manage your cookie settings and preferences.
* Learn about cookies: http://www.allaboutcookies.org/
* Opt out of Google's use of cookies: Ads Settings
* US Based
* UK Based
* Opt out of third-party vendor's use of cookies: Network Advertising
Initiative opt-out page
* DoubleClick opt-out page
* Manage companies' cookies (US) or EU based
* Manage cookies in your web browser
19.10 DO NOT TRACK
This website currently does not recognize Do-Not-Track signals from your web
browser.
You can stop email tracking using your email and privacy settings and
preferences. You should set your preferences to ‘do not track’.
Go back to the top of the page
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