This policy will be effective on April 15, 2020
We will strive to process your personal information lawfully, fairly, and in a transparent manner. Your personal information will be collected for specified, explicit and legitimate purposes that align with the services you have requested and not further processed in a manner that is incompatible with the requested services. Our processing of your information shall be limited to that which is adequate, relevant, and necessary to provide you the requested services. Once we have processed or stored your information we will use commercially accepted practices to protect your personal information, ensure it is accurate and up-to-date, and work with you to correct inaccuracies we find or you notify us exist. We do not, however, assert, claim, or ensure the personal information you provide or provided by others to us is accurate. We will use industry standard practices to provide you with requested services, store personal information, and maintain information regarding your use of the service for only as long as necessary to provide such services, and after such time retain personal information only as required for financial or legal reasons, or remains part of our normal archiving process. Such processes may include archiving--which shall remain offline and not available to the public, processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with GDPR Article 89(1). We implement industry standard practices to provide security and protect the confidentiality of your personal information against unauthorized or unlawful processing and against accidental loss, destruction or damage. We periodically update our standard practices which can be obtained upon request.
We will process your personal information for other purposes, beyond providing the requested services, when you provide consent in compliance with all State and Federal laws, when the processing is necessary to provide you the service you requested, to protect your vital interests or that of someone else, when necessary to accomplish a task in the public interest, and when necessary for us to perform standard business and technical processes where such processes do not override your rights or that of a minor. If we must process or store your personal information for any other reason, we will notify you and request your consent prior to processing.
1. Information You Provide to Us
We store information you provide directly to us. For example, we collect information when you become a user; create an online account or profile; use the interactive areas and features of our Cascadin Services; and when you provide information via email, phone calls, or otherwise communicate with us.
The types of information we may store include your name, address, phone number, fax number, email address, zip code, social media usernames, payment information, and any other information you choose to provide. Some of this personal information is defined as personally identifiable information (“PII”).
We will process and store your personal information on behalf of our Customer while you continue to use the requested services. Upon termination of your use of the services, we will, through the normal course of business and IT processes, erase your personal information from active repositories and erase your personal information from archives and backup storage. The length of time the information is kept will be within industry standards for information purging and retention.
During our normal course of business we do not collect, process, or store personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric information for the purpose of uniquely identifying a natural person, health information, or information concerning a natural person’s sex life or sexual orientation. Should such personal information come into our possession or be processed by us from other sources, including you providing such information, we will erase this type of information upon your request or maintain such information upon your request with explicit consent by you. Only with your consent or for compelling reasons enumerated in GDPR Chapter 2 Article 2(2) or as compelled by law will we collect, store, or process such information.
We will only store your personal information on behalf of our customer unless your use requires us to engage third-party payment processing, identify you or validate your age, or otherwise utilize software support service providers which will provide you with their privacy policies and terms and conditions for use. You will be prompted to provide opt-in consent for such sharing.
You understand and acknowledge that providing personal information may be a statutory or contractual requirement, or a requirement necessary to utilize the services, as well as whether you are obliged to provide the personal information and use of the site, services, or software may be denied as the result of a failure to provide such information.
2. Information We Collect Automatically
In some cases, we may also collect information about you provided by other users of Cascadin Services, such as your role, tasks, etc. Information may be captured based on your user profile and your interaction with Cascadin Services and such information may be utilized by algorithms to enhance your user experience or supplement personal information. We will use this information to enhance your use of Cascadin Services and you agree that we may collect such information by using the system. We will not share such information with any third parties or use such information for marketing communications to you or anyone connected to you unless you or they explicitly provide opt-in consent to receive these types of communications from us.
We may also automatically collect information about you when you access or use the Cascadin Services or transact business through our Services. However, if such information is uniquely linked to you, we will present you with a clear and concise opt-in choice for such collection which will include specifying what information we will collect, which may include:
- Transaction Information: When you use Cascadin Services or our Customer uses the Services to interact, collaborate, or otherwise act in conjunction with your use or information you create through the Services, we may collect information about you or the information you have accessed through the Services. This is meant to enhance use of the Services and is not an audit or evaluation function of the Services.
- Log/Signup Information: We obtain information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address or email address, and the page you visited before navigating to our Cascadin Services or which part of the services you used.
- Device Information: We collect information about the computer or mobile device you use to access our Cascadin Services, such as the hardware model, operating system and version, unique device identifiers, mobile network information, and browsing behavior.
- Location Information: We may collect information about your location when you access or use our Services and consent to the collection of this information. For more details, please see "Control Over Your Information" below.
We may use automated processing, including artificial intelligence, machine learning, and other techniques to process your information. We will not use any type of automated processing if such processing produces legal effects concerning you or similarly significantly affects you unless such processing is: (i) necessary for entering into, or performance of, a contract between you and us; or (ii) authorized by the State of Montana or US or international law to which we are subject and which also establishes measures to safeguard your rights, freedoms, and legitimate interests; or results from your explicit consent. In the case of (i) or (iii), we will implement reasonable measures to safeguard your rights, freedoms, and legitimate interests, and, where and when possible, involve human intervention on our part to express your point of view and to contest the decision. In the case of the most sensitive information, such as race, ethnicity, gender, and the like, we will provide industry standard measures to safeguard your rights, freedoms, and legitimate interests.
3. Our Use of Information for Internal Purposes
We use the information we collect about you for a variety of purposes, for example, to:
- administer your user account and communicate with you about user benefits;
- provide and deliver products and services, process and complete actions, and send you upgrade or defect correction information, including support and administrative messages;
- provide, maintain, and improve the Cascadin Services;
- investigate and prevent fraudulent actions and other illegal activities;
- respond to your comments and questions and provide user support services;
- communicate with you about the Services and support services and other information from our third-party contractors and service providers providing we think these communications and information will be of interest to you;
- monitor and analyze trends, usage, and activities;
- personalize the Cascadin Services and provide support, content, or features that are targeted toward your needs as a user;
- process and deliver documents and reports;
- provide your user data to our Customer who engages us on their behalf as a data processor; and
- carry out any other purpose for which the information was collected.
We are based in the United States and the information we collect is governed by Montana, US, and, in some instances, International law. By accessing or using our Cascadin Services or otherwise providing information to us, you consent to the processing and transfer of information within and into the US.
4. Our Disclosure of Personal Information to Third Parties
We may share personal information about you with our Customer, but only with third parties after being directed by our Customer and gaining your consent. However, some of this information sharing is required to process your request and provide you with service which means that withholding consent may prevent us from processing your request. Such information may include sharing for the following reasons:
- allow third parties to perform services on our behalf;
- with various third parties who help us provide, maintain, and improve the Cascadin Services we provide;
- with third parties where directed by our Customer and which, if required, you agree, to participate in the interactive areas of our Cascadin Services;
- during negotiations of a corporate business transaction such as a merger or acquisition of all or a portion of our business to another company, joint venture, corporate reorganization, insolvency or bankruptcy, financing or sale of company assets, but such sharing in these instances will be done under a Non-Disclosure Agreement that prevents your personal information from be obtained or retained by the other party;
- where a request for information is made in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule, or regulation;
- where necessary to enforce our agreements, policies, and Terms of Service or to protect the rights, property, and safety of Cascadin, our users, our customers, or any other persons.
5. Our Disclosure of Non-Personal Information to Third Parties
We may disclose non-personal Information, in aggregate and anonymized form, to potential strategic partners, advertisers, investors, customers, and others. You may opt-out of the sharing of this information if the information shared uniquely identifies you.
6. Third-Party Advertising, Analytics and Services
7. Social Sharing Features
The Cascadin Services may offer social sharing features or other integrated tools, which let you share actions you take on the Cascadin Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of information collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these features.
8. Control over Your Information
You have the right to request from us access to and correction or erasure of personal information or restriction of processing concerning your personal information as well as the right to data portability. You may update or correct your online account information by logging into your online account and updating your information or by emailing Customer Service at firstname.lastname@example.org. If you wish to deactivate your online account, you understand and agree that we may retain information about you for legitimate business purposes or as required by law. You have the right to obtain from us without undue delay rectification of inaccurate personal information concerning you. Taking into account the purposes of our processing of your information and our regular business and technical processes, you have the right to supply incomplete personal information, including by means of providing a supplementary statement.
You have the right to obtain from us the erasure of personal information concerning you without undue delay and we will have the obligation to erase personal information without undue delay when: (i) your personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) you withdraw your consent on which the processing is based providing there is no other legal ground for the processing or retaining of your personal information; (iii) you object to the processing and there are no overriding legal or legitimate grounds for the processing; (iv) we have inadvertently or unlawfully captured or processed your personal information; (v) your personal information must be erased in order to comply with a legal order issued by a court of proper jurisdiction or to comply with a statute to which we are subject; (vi) your personal information has been collected in relation to the offer of information society services referred to in GDPR Article 8(1). Where we have made your personal information public and are obligated to erase the personal information, we will, after taking account of available technology and the cost of implementation, take reasonable steps, including technical measures at our disposal, inform others which are processing or storing your personal information that you have requested the erasure by such others of any links to, or copy or replication of, your personal information. You acknowledge that such public information may never be completely erased despite our efforts. We may not be able to erase your information, specifically when continued processing or storage is necessary for: (i) exercising the right of freedom of expression and information; (ii) compliance with a legal obligation which requires processing or storage where such legal obligation stems from a legal order issued by a court of proper jurisdiction or compliance with a statute to which we are subject; (iii) reasons of public interest in the area of public health as specified in the GDPR; (iv) archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with those specified in the GDPR; (v) or to assert, exercise, or defend legal claims. We will act within one month unless the complexity and number of requests is excessive, in which case the time period may be extended up to two additional months but in such case, we will inform you.
If we intend to further process the personal information for any purpose other than that for which the personal information was obtained, we will provide you with information on that other purpose and with any relevant further information prior to the further processing. You may restrict us from processing your personal information if you inform us that you contest the accuracy of the information, or the processing is unlawful, or you request the information not be erased, or you request restriction of the processing, or we no longer require the personal information to provide the services the for which the personal information was obtained but are required by you for the establishment, exercise, or defense of legal claims, or we have legitimate grounds that override your grounds for requesting restriction. If processing is restricted at your request, your personal information will only be processed with your consent, or for the establishment, exercise, or defense of legal claims, or to protect the rights of another natural or legal person for reasons of compelling public interest as deemed by the State of Montana or the U.S. Under all circumstances we will inform you prior to resuming the processing of your personal information.
You will have the right to obtain from us information as to whether your personal information is being processed, and if so, (i) be informed of the purpose of the processing; (ii) be informed of the categories of personal information processed; (iii) be informed of the recipients or categories of recipient to whom the personal information have been or will be disclosed, if any; (iv) be aware, if possible, of the time period for which the personal information will be stored, or, if not possible, the criteria used to determine that time period; (v) be afforded the existence of the right to request from us, or a third party, rectification or erasure of personal information or restriction of processing of your personal inform, or object to such processing; (vi) have the right to submit a complaint to us or the appropriate third party; (vii) have the right to request the source of any information not collected directly from you; (viii) be notified if your personal information is utilized by algorithms to enhance your user experience or supplement personal information; and (ix) the right to obtain a copy of the personal information undergoing such processing and you agree to pay a reasonable fee if requested for a copy of your personal information being so processed, providing obtaining such a copy does not adversely affect the rights and freedoms of others.
You have the right to object to the processing of your personal information if such processing is performed in the public interest, or in the exercise of official authority vested us, or for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information, in particular where the personal information is of, about, or in contains information about a child. If we process your personal information for direct marketing we will notify you prior or concurrent to such processing and you may object to processing of your personal information for such purpose. Where your personal information is processed for scientific or historical research purposes, or statistical purposes pursuant to GDPR Article 89(1), you may, on grounds relating to your particular situation, object to processing of your personal information, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
We will inform you and any third parties when your personal information has been rectified or erased or is subject to a restriction of processing. We will inform you as to which third parties we have contracted with as well.
You have the right to receive your personal information you provided to us in a structured, commonly used and machine-readable format of our choice and have the right to provide such information to any party of your choosing without restriction or hindrance from us. If practicable, and at our sole discretion, we may provide your personal information to a third party upon your request. Receiving your information has no impact or relationship to decisions you may make regarding erasure of your personal information nor adversely affect the rights of others.
9. Promotional Communications
You may opt-out of receiving promotional communications from the Site by following the instructions in those communications or changing your preferences via your account preferences. If you opt-out of receiving promotional communications, we may still send you non-promotional emails, such as emails about your purchases, account, or our ongoing business relations.
10. Location Information
We do not collect GPS generated location information at this time, but may collect physical addresses from you or IP addresses that give general location information. Such information will not be kept to monitor or receive information about a user’s locations over time.
11. How We Protect Your Personal Information
We consider protecting the security of your personal information as very important. We follow generally accepted industry standards to protect personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we do not guarantee absolute security. We are not responsible for the unauthorized acts of others and we assume no liability for any disclosure of information due to errors in transmission, unauthorized third-party access (such as through hacking) or other acts of third parties or acts or omissions beyond our reasonable control.
12. Changes to this Policy
Cascadin may change this Policy from time to time. If we make changes, we will notify you by revising the Effective Date above and, in some cases, we may provide you with more prominent notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Policy to stay informed about our information practices and the ways you can help protect your privacy.
13. Contact Us
If you have any questions, comments or concerns about this Policy or about our privacy practices, please send an email message to email@example.com. Should you wish to have your information erased or corrected, contact us as firstname.lastname@example.org with the subject line “Attention Data Protection Officer” and we’ll then engage the Officer in responding to your request. You may also direct your privacy-related comments or questions to the following address: 90 W Madison Ave Ste. E-136, Belgrade, MT 59714.