Privacy Policy
Last Modified: July 2, 2019
Introduction
This Causeway website (“Website”) is a service of Vital Technical Marketing, Inc., dba VTM Group, (“VTM” or “We”) provided to the company or organization through which you are accessing this Website (“Company”). We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (“Policy”). This Policy describes the types of information we may collect and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy is supplemented by and includes our Privacy Shield Policy and GDPR Compliance Policy.
If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
We have recently updated this Policy in our effort to be a compliant data processor under the GDPR. Please see our section on GDPR Compliance.
What information do we collect?
We collect information from you when you register on this Website, that you may provide when you visit the Website, and that is generated by the use of the Website by you and others. We collect the following types of information:
- Personally identifying personal data (Name only),
- Social network personal data (LinkedIn and Twitter),
- Computer device personal data (IP Address only), and
- Professional and professional contact personal data.
This information is collected through the following means:
- When registering on Causeway, you will be required to enter your name, the company you work for, and your work e-mail address. All of this information is required to have an account on this Website. You will also have the option to select your country.
- When registering on Causeway and in your user profile, you will also have the option to enter additional information: phone number, mailing address, job title, and LinkedIn and Twitter URLs (“Optional Data”). This data may be edited or deleted by you at any time via your user profile.
- When you and others use the Website, information is automatically collected as you and others navigate and use the functions of the Website (“Activity Data”), which includes work group use, tasks assigned or performed, voting, calendar entries, wiki and document creation and edits, discussions sent, and news posts. Activity Data is also kept in user activity logs, which also include your IP address.
Activity Data includes your contributions to the Website (“User Contributions”), such as wiki creation and edits, voting, discussions, and news posts. Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages and the Website overall, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website who may have access to your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Accessing and Correcting Your Information
You can review and change or delete your Optional Data at any time by logging into the Website and visiting your account profile page.
To understand the personal data that can be deleted and circumstances for doing so, you must contact the administrator(s) of the Website.
Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Service.
What do we use your information for?
Any of the information we collect from you may be used in any of the following ways:
- To carry out our obligations and enforce our rights arising from our agreement to provide a Causeway site to the Company (your User Contributions are a key part of the Service we provide under our agreement with the Company)
- To personalize your experience (your information helps us to better respond to your individual and the Company’s needs)
- To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
- To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
- To send periodic emails (The email address you provide may be used to send you information, respond to inquiries, and/or other requests or questions)
How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.
We offer the use of a secure server. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology and then entered into our Database. This information is only accessed by individuals who are authorized with special access rights to our systems, and who are required to keep the information confidential.
We do not collect or store private information such as credit card numbers, social security numbers, or other sensitive financial information within Causeway.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Do we use cookies?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site or service provider systems to recognize your browser and capture and remember certain information. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
We use cookies to track your activity while using the Website. The unique Session ID that is stored in the cookie is also stored on our server for a period of 3 hours and is then deleted.
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating the Website, conducting our business, or servicing you or the Company, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. We may use Google Analytics to analyze traffic and usage of our services. You can find out more information about Google Analytics cookies here: https://policies.google.com/technologies/partner-sites. To opt-out of Google Analytics relating to your use of our Sites, you can download and install the Browser Plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
California Online Privacy Protection Act Compliance
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.
As part of the California Online Privacy Protection Act, all users of our Website may make any changes to their information at any time by logging in to Causeway and going to the 'My Profile' page.
Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed and intended to people who are at least 13 years old or older, and no one under age 13 may provide any information to or on the Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@causeway.com.
Online Privacy Policy Only
This online privacy policy applies only to information collected through our website and not to information collected offline.
Your Consent
By using our site, you consent to this Policy.
Changes to our Privacy Policy
If we decide to change this Policy, we will post those changes on this page, and/or update the Policy modification date below. If we make material changes to how we treat our users' personal data, we will notify you through a notice on the Website home page or by email to the email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
This Policy was last modified on April 10, 2019.
Contacting Us
If there are any questions regarding this Policy, you may contact us using the information below.
Causeway c/o VTM Group
3855 SW 153rd Drive
Beaverton, OR 97003
USA
inquire@causewaynow.com
+1.503.619.0583
Last Modified: July 2, 2019
Introduction
This GDPR Compliance Policy describes how Vital Technical Marketing, Inc., dba VTM Group, in the United States (“US”) (“VTM,” “we,” or “us”) processes certain personal data that we receive in the US from the European Economic Area (“Personal Data”). This GDPR Compliance Policy supplements our Website Privacy Policy only insofar as you are an EU Data Subject as defined below, and unless specifically defined in this GDPR Compliance Policy, the terms in this GDPR Compliance Policy have the same meaning as the Website Privacy Policy.
Definitions
- “Data Protection Legislation” means the Regulation (EU) 2016/679, commonly known as the Global Data Protection Regulation or GDPR.
- “EU Data Subject” means an individual located in the European Union and the countries of Iceland, Liechtenstein and Norway and, if applicable, Switzerland.
Any term not defined herein has the same meaning as it is defined under the Data Protection Legislation if and only if it is specifically defined under the Data Protection Legislation.
Data Processor
VTM is the data processor on behalf of the Company processing data via Causeway. The Company is the data controller.
Data Collection and Processing
VTM processes the personal data set out in the section of the Website Privacy Policy titled ‘What information do we collect? and for purposes set out in the section of the Website Privacy Policy titled ‘What do we use your information for?’. A full table setting out all the information collected and its deletion and retention policy is set forth at the very bottom of this GDPR Compliance Policy - Personal Data Deletion and Retention Policy Table.
Basis for Processing
VTM processes your personal data to fulfill its contractual obligations under VTM’s Service Agreement with the Company and as a result of your express consent to the Privacy Policy and Terms of Service and your implied consent in continuing to use this Website.
Sharing of Your Personal Data
VTM only shares your personal data with the Company or VTM’s sub-processor Amazon Web Services (“AWS”).
Your Rights
As the data controller, the Company is your point of contact to enforce your rights under the Data Protection Legislation. However, to assist with the Company’s obligation of transparency, we have set forth the table below to help you enforce your rights.
- Right to access personal data about you: You can ask the Company, who is an administrator of the Website, if they are processing your personal data via the Website. If so, the Company can also provide you with a copy of that personal data.
- Right to object to processing: You may contact the Company, who is an administrator of the Website, and ask them to have us stop processing your personal data.
- Right to data portability: You may contact the Company, who is an administrator of the Website, and ask them for a copy of your personal data.
- Right to complain: You have the right to report a problem with the way we have handled your personal data with the data protection authority that is authorized to hear your concern.
- Right to object to automated decision making: As we don’t have any decisions based upon automated decision making, this right is fully met by the Company’s agreement with VTM.
- Right to rectification: The Optional Data (as described in the section of the Website Privacy Policy titled ‘What information do we collect?’ can be modified at any time via your user profile. All other personal data can be modified by contacting the Company, who is an administrator of the Website.
- Right to be forgotten: The Optional Data (as described in the section of the Website Privacy Policy titled ‘What information do we collect?’ can be deleted at any time via your user profile. You may contact the Company, who is an administrator of the Website, and ask them to delete any other information. Where possible, the Company’s administrator can delete your personal data or have it anonymized.
Personal Data Deletion and Retention Policy Table
|
Personal Data |
Retention Policy and Procedures |
|
Account Data:
|
The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, the information is kept for the life of the Agreement between Company and VTM. |
|
Optional Account Data:
|
This data is optional and may be edited and/or deleted at any time by the end-user via their profile. Otherwise, the information is kept for the life of the Agreement between Company and VTM. |
|
Cookies:
|
The unique Session ID that’s stored in the cookie is also stored on the Causeway server file system (on AWS) for a period of 3 hours and is then deleted. |
|
Work Group
|
The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, the information is kept for the life of the Agreement between Company and VTM. |
|
Tasks
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The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, the information is kept for the life of the Agreement between Company and VTM. |
|
Voting
|
The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, this information is kept for the life of the Agreement between Company and VTM. |
|
Calendar
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The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, this information is kept for the life of the Agreement between Company and VTM. |
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Wiki
|
The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, the information is kept for the life of the Agreement between Company and VTM. |
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Discussions
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The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, the information is kept for the life of the Agreement between Company and VTM. |
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Documents
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The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, the information is kept for the life of the Agreement between Company and VTM. |
|
News
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The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, the information is kept for the life of the Agreement between Company and VTM. |
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User Activity Log:
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The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, this information is kept for the life of the Agreement between Company and VTM. |
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Outgoing Email Log:
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The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, this information is kept for the life of the Agreement between Company and VTM. |
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Inactive User Log:
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The Company site administrator has the ability to anonymize a user’s data as set forth above. Otherwise, this information is kept for the life of the Agreement between Company and VTM. |
Causeway – Privacy Shield Policy
Last Modified: July 2, 2019
This Privacy Shield Policy (“Shield Policy”) describes how Vital Technical Marketing, Inc., dba VTM Group, in the United States (“US”) (“VTM,” “we,” or “us”) collects, uses, and discloses certain personally identifiable information that we receive in the US from the European Economic Area (“EEA Personal Data”) and Switzerland (“Swiss Personal Data”). This Shield Policy supplements our Website Privacy Policy, and unless specifically defined in this Shield Policy, the terms in this Shield Policy have the same meaning as the Website Privacy Policy.
VTM complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. VTM has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
Personal Data Collection and Use
Our Website Privacy Policy describes the categories of EEA and Swiss Personal Data that we may receive in the US as well as the purposes for which we use that EEA and Swiss Personal Data. We process EEA and Swiss Personal Data for the following primary purpose: to fulfill our contractual obligations and carry out our rights under our agreement with the company or organization through which you are accessing this Website (“Company”). Other purposes for which we process EEA and Swiss Personal Data include those set out in ‘What do we use your information for?’. VTM will only process EEA and Swiss Personal Data in ways that are compatible with the purposes that VTM collected it for, or for purposes the individual later authorizes. Before we use your EEA and Swiss Personal Data for a purpose that is materially different than the purposes we collected it for or that you later authorized, we will provide you with the opportunity to opt out. VTM maintains reasonable procedures to help ensure that EEA and Swiss Personal Data is reliable for its intended use, accurate, complete, and current.
We do not collect any category of sensitive EEA and Swiss Personal Data.
Data Transfers to Third Parties
Third-Party Agents or Service Providers. We may transfer EEA and Swiss Personal Data to our third-party agents or service providers who perform functions on our behalf. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EEA and Swiss Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EEA and Swiss Personal Data that we transfer to them.
If we transfer your EEA and Swiss Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your EEA and Swiss Personal Data is protected with the same level of protection the Privacy Shield requires.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EEA and Swiss Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Security
VTM maintains reasonable and appropriate security measures to protect EEA and Swiss Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
Access Rights
You may have the right to access the EEA and Swiss Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EEA and Swiss Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints and Independent Recourse Mechanism
In compliance with the Privacy Shield Principles, VTM commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact VTM at:
Causeway, c/o Lindsay Adamson
3855 SW 153rd Drive
Beaverton, OR 97003
USA
+1.503.619.0853
VTM has further committed to refer unresolved Privacy Shield complaints through an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Binding Arbitration
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with VTM and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).
Contact Us
If you have any questions about this Shield Policy or would like to request access to your EEA and Swiss Personal Data, please contact us as follows:
Causeway, c/o Lindsay Adamson
3855 SW 153rd Drive
Beaverton, OR 97003
USA
+1.503.619.0853
Changes to This Policy
We reserve the right to amend this Shield Policy from time to time consistent with the Privacy Shield's requirements.
Last Modified: July 2, 2019