Cincom Privacy Policy

Cincom Systems, Inc., its subsidiaries and affiliates (collectively, “Cincom”, “we”, “us” or “our”) appreciates your interest in our products and services, and we are aware that you are concerned as to how the information you provide to us is used and shared with others. Cincom adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (“EU”) to the United State of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. The Principles can be found at http://export.gov/safeharbor/eu/eg_main_018475.asp. If there is any conflict between this privacy policy and the Principles with respect to such a transfer, the Principles will govern. We have established a comprehensive privacy program, including a global privacy office and a Chief Privacy Officer, designed to help us respect and protect your data privacy rights. This statement includes both Cincom’s European Union- U.S. Safe Harbor Privacy Statement and the website privacy statement. It describes Cincom’s Privacy Policy, including the types of information we gather, how we use it, and the notice and choice affected individuals have regarding our use of and their ability to correct that information. The following Privacy Policy applies to all Personal Information received by Cincom whether in electronic, paper, or verbal format, other than Personal Information transferred between the European Economic Area (EEA) and the United States. (See the Safe Harbor Privacy Statement below for information on transfers of information from the EEA.)

What kind of information does Cincom collect?

We typically collect two kinds of information about you: (a) information that you provide that personally identifies you; and (b) information that does not personally identify you that we automatically collect when you visit our website or that you provide us.

(1) Personal Information: As a general policy, we do not automatically collect your Personal Information when you visit our website. In certain circumstances, we may request, collect, or otherwise provide you an opportunity to submit your Personal Information in connection with certain activities on our website, including but not limited to:

  • Participation in a survey or questionnaire
  • Registration Screens and online forms
  • Delivery and address information from Cincom carriers and/or other third parties – this information is used to update our records and make future communication easier
  • The articles you select to read are captured and entered into a personal interest profile.

Our definition of “Personal Information” means personally identifiable information and includes any information that may be used to specifically identify or contact you, such as your name, address (mailing or email), phone number, etc. and includes Sensitive Information. We do not knowingly collect Sensitive Information (personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual) when we request Personal Information. Whether or not you provide this Personal Information is your choice; however, in many instances this type of information is required to participate in the particular activity, realize a benefit we may offer, or gain access to certain content on our Website.

(2) Non-Personal Information: Non-personal information is any information that does not personally identify you. Non-personal information can include certain Personal Information that has been de-identified; that is, information that has been rendered anonymous. We obtain non-personal information about you from information that you provide us, either separately or together with your Personal Information. We also automatically collect certain non-personal information from you when you access our website. This information can include, among other things, IP addresses, the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, etc.), the third party website from which your visit originated, the operating system you are using (e.g., Vista, Windows XP, Mac OS, etc.), the domain name of your Internet service provider (e.g., America Online, NetZero, etc.), the search terms you use on our website, the specific web pages you visit, and the duration of your visits.

What does Cincom do with the Personal Information you provide?

We use the Personal Information you submit to us to:

  • Respond to your requests
  • Personalize some of the web content and promotions based on your personal-interest profile so that our website becomes increasingly relevant to your needs
  • Provide input on your particular needs to our marketing and sales organizations to make current marketing and sales initiatives increasingly relevant to your needs
  • Communicate product or services information that might be useful or urgent in nature, including product performance issues or fixes
  • Communicate significant website changes or web content information
  • Provide future service and support

We use non-personal information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities, and to improve our services. We may use your non-personal information by itself or aggregate it with information we have obtained from others. We may share your non-personal information with our affiliated companies and third parties to achieve these objectives and others, but remember that aggregate information is anonymous information that does not personally identify you.

What about “cookies” and web beacons?

We automatically receive and store certain types of non-personal information whenever you interact with us. For example, like many websites, we use “cookies” and “web beacons” (also called “clear gifs” or “pixel tags”) to obtain certain types of information when your web browser accesses our website. “Cookies” are small files that we transfer to your computer’s hard drive or your Web browser memory to enable our systems to recognize your browser and to provide convenience and other features to you, such as recognizing you as a frequent user of our website. “Web beacons” are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, and to provide other information.

Examples of the information we collect and analyze in this manner include the Internet protocol (IP) address used to connect your computer to the Internet; computer and connection information such as browser type and version, operating system, and platform; your behavior on our Website, including the URL you come from and go to next (whether this URL is on our site or not); and cookie number.

What are Cincom’s security measures?

Cincom takes steps we consider reasonable to protect Personal Information collected via this website from loss, misuse, and unauthorized access, disclosure, alteration and destruction. Cincom has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Keep in mind, however, that despite such reasonable safeguards, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information. . In the unfortunate event that your Personal Information is compromised, we may notify you by e-mail (at our sole and absolute discretion except where required by law) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.

Under what circumstances does Cincom share information?

Cincom does not sell, trade or rent your Personal Information to others. Unless we have your permission or are required by law, we will only share the Personal Information you provide online with other Cincom entities and/or business partners who are acting on our behalf to complete the activities described above. You will be given the opportunity to opt out: (i) if we decide to share your information with a third party (unless that third party is acting as an agent to perform tasks on behalf of us and under our instructions); or (ii) if it is to be used for a purpose that is incompatible with the purposes for which it was originally collected or subsequently authorized by you. We do not share Sensitive Information with anyone under any circumstances.

Business partners receiving Personal Information are required to maintain confidentiality and to apply security protection that is consistent with this Privacy Policy. We will ensure that any third party to whom Personal Information may be disclosed agrees in writing to provide an adequate level of privacy protection. These companies are authorized to use your Personal Information only for the purpose it was originally provided or as authorized by you.

U.S. – EU Safe Harbor Privacy Statement

For Personal Information of employees, consumers, healthcare professionals, medical research subjects and investigators, customers, investors, and government officials that Cincom receives from the European Economic Area, Cincom has committed to handling such Personal Information in accordance with the Safe Harbor Principles (the “Principles”). For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s website at http://export.gov/safeharbor/eu/eg_main_018475.asp.

This Safe Harbor Privacy Statement sets forth the following Safe Harbor Principles that Cincom follows with respect to Personal Information transferred between the European Economic Area (which includes the member states of the European Union) and the United States.

Notice. When Cincom collects and uses Personal Information, it will inform the individuals to whom the information pertains about the purposes of such collection and usage, how to contact Cincom with any inquiries or complaints, the types of third parties to which Cincom discloses such information, and the choices and means Cincom offers individuals for limiting its use and disclosure. This notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Cincom or as soon thereafter as is practicable, but in any event before Cincom uses such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party.

Choice. Cincom will offer individuals the opportunity to choose (opt out) whether their Personal Information is (a) to be disclosed to a third party or (b) to be used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual. Individuals will be provided with clear and conspicuous, readily available, and affordable mechanisms to choose. For Sensitive Information, individuals will be given affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual through the exercise of opt in choice.

Onward Transfer. To disclose Personal Information to a third party, Cincom will apply the Notice and Choice Principles. Where Cincom wishes to transfer information to a third party that is acting as an agent, it will first either ascertain that the third party subscribes to the Principles or is subject to the European Commission’s Directive on Data Protection or another adequacy finding, or enter into a written agreement with such third party requiring that the third party provide at least the same level of privacy protection as is required by the relevant Principles. If Cincom complies with these requirements, it will not be held responsible (unless Cincom agrees otherwise) when a third party to which it transfers such information processes it in a way contrary to any restrictions or representations, unless Cincom knew or should have known the third party would process it in such a contrary way and Cincom has not taken reasonable steps to prevent or stop such processing.

Security. Cincom will take reasonable precautions to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity. Cincom will process Personal Information in a way that is compatible with the purposes for which it has been collected or subsequently authorized by the individual. To the extent necessary for those purposes, Cincom will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete, and current.

Access. Individuals can access Personal Information about them that Cincom holds and will be able to correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

Enforcement. Cincom uses a self-assessment approach to assure compliance with this Privacy Statement and regularly reviews its compliance with the Principles. Any employee that Cincom determines is in violation of this Policy will be subject to disciplinary action including termination of employment or other form of association with Cincom.

Dispute Resolution. We encourage interested persons to raise any questions or concerns regarding the use or disclosure of Personal Information by contacting the Chief Privacy Officer of Cincom, at the address given below. We request that any question or concern about Personal Information be submitted in a writing providing the details of the issue in order for the Chief Privacy Officer effectively to evaluate the issue. The Chief Privacy Officer will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Cincom and the complainant, Cincom elects to participate in the dispute resolution procedures of JAMS. For more information, see http://www.jamsadr.com/safeharbor/.

Applicable to Cincom Privacy Policy and Safe Harbor Privacy Statement

Links to Websites Outside Cincom

This Privacy Policy contains links to other websites that may be of interest to you. These links are provided as a courtesy of Cincom, and it is likely that the owners of these sites have their own privacy policies separate from those of Cincom. We suggest that you review these privacy policies before providing personal information. Cincom will have no responsibility or liability for any of these links.

Your Consent

BY VISITING CINCOM’S WEBSITE, YOU ARE ACCEPTING THE POLICIES THAT ARE DESCRIBED IN THIS PRIVACY POLICY AND CONSENTING TO THE COLLECTION AND USE OF INFORMATION BY CINCOM. WE WILL POST ANY CHANGES TO THIS POLICY WE MAY MAKE FROM TIME TO TIME ON OUR WEBSITE. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP ACCESSING OUR WEBSITE

Contact Information

Questions or comments regarding this Privacy Policy should be submitted to our Privacy Officer by e-mail as follows: kbyrne@cincom.com.

You can also reach us by U.S. mail:

Cincom Systems, Inc.
55 Merchant Street
Cincinnati, Ohio 45246
Attn: Privacy Officer

Changes to Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the Principles. The effective date of the Policy may be found on the first page of the Policy.
If you submitted Personal Information to us prior to the above effective date, and desire to opt out of having that previously submitted Personal Information from being treated under the new policy, please contact us at the above address.

Definitions

Agent means any person or third party that collects or uses Personal Information under the instructions of, and solely for, Cincom or to whom Cincom discloses Personal Information for use on Cincom’s behalf.

Personal Information means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to physical, physiological, mental, economic, cultural or social identity.

Sensitive Information is defined as Personal Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual.

Privacy Officer means the individual responsible for internal audit of processes and procedures to safeguard Personal Information and for ensuring that transfers are consistent with applicable law.

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Effective: 01.06.2012

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