We have supplemented our Privacy Policy to reflect the requirements of the California Consumer Privacy Act (“CCPA”), effective 1st January 2020. The CCPA sets forth the restrictions on how CallisonRTKL can use the data of California residents.
1. Summary
CallisonRTKL Inc. (“CallisonRTKL” or “CRTKL”) is committed to protecting and respecting your privacy and abiding by the spirit and intent of the CCPA. This policy explains what information we may collect from you, how and why we collect it, who it may be shared with, and what your rights are to ask us to know the information we have collected and to request that we delete that information. We may change this policy without warning, but we will post any changes on this page. Please read it carefully.
By using our website and agreeing to this policy, you consent to the terms of this policy, as well as our use of cookies in accordance with the terms of this policy.
2. Information we have collected from you in the past 12 months, how and why we collect it, and who it may be shared with.
2.1 Comments
When visitors leave comments on our website, we collect the data shown in the comments form. We also collect the visitor’s IP address and browser user agent string to aid in spam detection. This information assists CRTKL in measuring and understanding the effectiveness of the content we provide in our website and other digital channels and assists in administering our websites and other digital channels for internal business administration (for example, troubleshooting, data analysis, testing, research, statistical and survey purposes). This information may be shared with our subsidiaries and affiliates as well as with service providers who host our web servers, provide spam filtering, or analyze our data.
2.2 Contact Forms
If you contact CRTKL or register to receive email updates through forms on our site, we collect information used to respond to your inquiry, including your name, email address and message. We will also collect your IP address and browser user agent string to aid in spam detection. This information allows us to provide you with both the information and/or services you request from us and assist in internal business administration as noted above. This information may be shared with our subsidiaries and affiliates, our web master, as well as with service providers who host our web servers, provide spam filtering, or analyze our data. Depending on the nature of the inquiry, this information may also be shared with our office managers or other CRTKL employees as needed to address your inquiry.
2.3 Cookies
We use cookies and other similar technologies to distinguish you from other users of our websites and digital channels. These cookies originate with us as well as various so-called plug-ins (i.e., third-party add-ons) that give our site more functionality. Cookies help us to provide you with an enhanced experience when you visit our site and allow us to audit consumer interactions to understand how people use our website and determine what aspects of our website they are interested in. Cookies last for fourteen months. You may adjust the settings on your browser to refuse cookies. As noted below, we share cookie information with Google Analytics.
2.4 Embedded content from other websites
Items on our website may include embedded content (e.g., videos, images, articles, etc.) from other websites including YouTube, Vimeo, Twitter, Facebook, and Instagram. Embedded content behaves in the exact same way as if you have visited that other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
2.5 Analytics
CallisonRTKL uses Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie with a randomly generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have – or ask us to delete any Google Analytics data – please delete your cookies, reach out to our Privacy Officer at the email at the end of this Policy, and/or install the Google Analytics Opt-Out Browser Add-On.
2.6 Website and Digital Channel Visitors
When you use our websites or digital channels, we may automatically collect information about your device, including your IP address, information about your visit (including how you got to our website) and how you use our digital channels. We may combine this information with other information you have provided to us or which we have received from other sources. This information allows us to measure and understand the effectiveness of the content we provide in our website and other digital channels. It also assists in administering our website and other digital channels for internal business administration as noted above. Finally, this information helps protect our interest and those of third parties as part of our efforts to keep our network and content safe and secure. This information may be shared with our subsidiaries and affiliates as well as with service providers who host our web servers, provide spam filtering, or analyze our data.
2.7 Legal Process
We may disclose your personal information when required to do so by law or in response to a request from law enforcement or another regulatory authority. We may also disclose your personal information to enforce our agreements with you (if any) or to protect the rights, property or safety of CRTKL, its users or others. This includes sharing personal information with other organizations for fraud prevention purposes.
3. Your rights regarding information we have collected in the past 12 months
3.1 You have the right to know a) the categories of personal information that CRTKL has collected about you; b) the categories of sources from which the personal information is collected; c) the business or commercial purpose for which the information is collected; d) the categories of third parties to whom CRTKL has disclosed or sold your personal information; and e) the business or commercial purpose for which we disclosed or sold the information. Note that CRTKL does not and will not sell your personal information.
3.2 You have a right to ask about the specific pieces of information that we have collected about you. In certain circumstances, we have the right to deny your request.
3.3 You have a right to ask that we delete personal information that we have collected about you. In certain circumstances, we have the right to deny your request.
3.4 You have the right, and we commit, not to discriminate against you if you exercise your rights under the CCPA. For example, we cannot deny you goods or services or charge you different prices because you exercised your CCPA rights.
3.5 You may submit a request to know or a request to delete your information, by calling 844-922-7855 (844-92-CRTKL) or by completing the interactive web form.
4. Sale of Personal Information
CallisonRTKL does not and will not sell your personal information.
5. Verification of requests to know or delete information
5.1 CRTKL must verify your identity before it can grant your request to know or delete information. The level of verification depends on the nature of the information that you have asked to know or delete.
5.2 If you submit a request to know categories of information we have collected from you, we will verify your identity to a reasonable certainty by matching at least two pieces of personal information provided by you with the information maintained by us. In some cases, there is no reasonable method by which we can verify your identity to the degree required. For example, if you visited our website and we collected your IP address and other information as described above, we may be unable to verify your identity as this information is not correlated with any individual person or account.
5.3 If you submit a request to know specific pieces of personal information we have collected from you, we will verify your identity to a high degree of certainty by matching at least three pieces of personal information provided by you with the information maintained by us. We may also request that you provide a declaration signed under penalty of perjury, confirming that you are the individual whose personal information is the subject of the request.
5.4 If you submit a request to delete information we have collected from you, the level of verification will depend on the sensitivity of the personal information. Non-sensitive information will require that we match at least two pieces of personal information provided by you with the information we have collected from you. Sensitive information will require that we match at least three pieces of personal information provided by you with the information we have collected from you; you will also have to provide a signed declaration under penalty of perjury, confirming that you are the individual whose personal information is the subject of the request.
5.5 CRTKL is not required to respond to more than one request to know submitted by or on behalf of the same consumer in a 12-month period.
5.6 If CRTKL cannot verify that the person submitting or authorizing the request to know or delete is the person about whom we have collected information, we will deny the request.
5.7 In response to a request to know, we will not disclose an individual’s social security number, driver’s license number, other government-issued identification number, account password, or security questions or answers.
5.8 You can ask an authorized agent to submit a request to know or delete personal information on your behalf. In that case, CRTKL will require you to a) provide your authorized agent with written permission to submit the request to know or delete information on your behalf, and b) verify your identity with us using the methods described above. CRTKL may deny a request from an agent who fails to submit proof that they have been authorized to act on your behalf.
6. Personal Information regarding minors
CRTKL does not knowingly collect or solicit personal information from minors under the age of 13 and does not knowingly allow minors to use our website. If you are under the age of 13, do not register to receive our email updates or provide us with your information. If CRTKL learns that it has collected personal information about a minor without verified parental consent, we will delete that information immediately. If you believe that we might have collected information from or about a minor, please contact us at PrivacyOfficer@crtkl.com.
7. Do Not Track (DNT) signals
Some web browsers may transmit “do not track” signals to the websites with which the user communicates. CRTKL does not currently take action in response to those signals.
8. Links to third-party websites
Our website and digital channels may contain links to other websites. This privacy policy does not apply to those websites and we do not accept liability for the content of any other website. We recommend that you review their privacy policies before you provide them with any personal information.
9. Protection of Personal Information
CRTKL has in place measures that protect the personal information we collect about you from unauthorized, improper, or unlawful access, use, disclosure, alteration, or destruction.
10. Contact us
If you have questions about this privacy policy or the way in which CRTKL processes your personal information, you can contact us using the details below:
Data Protection Officer
CallisonRTKL Inc.
PrivacyOfficer@crtkl.com
Last Policy Update: January 1, 2020