CVG Strategy – EU Privacy Policy and Notice

CVG Strategy has prepared this Privacy Policy and Notice to conform to the EU GPDR and US Privacy Regulations.

Effective date: May 25, 2018

Introduction:

The data controller for cvgstrategy.com (the “Site”) is CVG Strategy, LLC (“CVG Strategy”, “we”, “us”, “our”). We are committed to fulfilling our responsibilities under the European Union’s General Data Protection Regulation (“GDPR”) in relation to the collection, retention, use, and other processing of personal data that is obtained when EU data subjects visit and interact with the Site. This Privacy Notice sets forth how we process EU personal data in our role as a data controller (i.e., when we are responsible for determining the purpose and means of the processing).

This CVG Strategy Privacy Policy covers:

Personal Data We Collect

CVG Strategy may collect and process the following information when you visit the Site.

  • Contact data. You may provide us with your contact details, such as name, email address, physical address, phone number, email address, or other similar information, which we may use to respond to you or for administrative purposes.
  • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Site and record that data in log files. This log data may include your Internet Protocol (IP) address, the address of the web page visited before using the Site, browser type and settings, the date and time the Site was used, information about browser configuration and plugins, language preferences, and cookie data.
  • Device Information. CVG Strategy may obtain information about devices that access the Site, including the type of device, its operating system, device settings, unique device identifiers, and crash data.
  • Authentication Data. To verify the identity of registered users on the Site we may collect a user name, password, password hint(s), and other similar authentication information.
  • Other Information You Provide. This includes emails and other communications that you send us or otherwise contribute, such as customer support inquiries and reviews. If you purchase a product, this will include information that is necessary to complete your purchase such as your credit card information. Please be aware that information you post on public parts of our website may be visible to anyone.

Note that our Site is dynamic. We may introduce new features, which may involve new or different personal data processing activities. If we make a material change to how we process your personal data, we will notify you and may also modify this Privacy Policy and Notice.

We Use Your Personal Data – How and Why

We may use the personal data we obtain to:

  • Communicate with you
  • Provide you with customized services
  • Ensure the security and integrity of our Site
  • Maintain and promote the Site
  • Analyze and learn about how the Site is accessed and used
  • Manage our customer and partner relationships
  • Enforce our legal terms and policies
  • Protect our and others’ interests, rights, and property
  • Comply with applicable legal requirements.

We process your personal data pursuant to the following legal bases:

  • You have consented to the use of your personal data. When you consent, you can change your mind at any time.  
  • The processing is necessary for us to provide you with the services and products you request, or to respond to your inquiries.
  • We have a legal obligation to process your personal data, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
  • To protect your vital interests, or those of others.
  • We have a legitimate interest in using your personal data. In particular, we have a legitimate interest in the following cases:
    • To analyze and improve the safety and security of our Site. This includes implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.
    • To maintain and improve the Site.
    • To operate the Site and provide you with certain tailored advertising and communications to develop and promote our business.
    • To anonymize personal data and subsequently use the anonymized information.

How We May Share Your Personal Data

We may share your personal data:

  • With our affiliates or business partners when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the Site.
  • With our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, ship your order, provide loyalty rewards, authorize and process your payments, manage our advertisements on other websites, send marketing and other communications on our behalf, or assist with data storage.
  • In order to follow the law or protect rights and interests. For example, we may disclose your personal data if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms of Use), or prevent fraud or abuse. In particular, we may disclose your personal data in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
  • If we are involved in a reorganization, merger, acquisition, or sale of some or all of our assets.

We Protect Your Personal Data

We maintain appropriate technical and organizational safeguards designed to help protect personal data from unauthorized disclosure or access and accidental or unlawful destruction, loss, or alteration. Although we use reasonable efforts to safeguard personal data, we cannot guarantee the security of your information obtained through the Site.

How Long We Retain Your Personal Data

We will store your personal data for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal data from our systems and records or take appropriate steps to properly anonymize it.

We Use Cookies and Other Similar Technologies

To improve our Site, CVG Strategy may use the following “cookies” to track your visit:

ProviderCVG Strategy Privacy Policy Purpose
QuantcastTo tracking and log user actions for advertising purposes.
DoubleClickTo tracking and log user actions for advertising purposes and managing ad operations.
AppNexusTo tracking and log user actions for advertising purposes.
Yahoo DOT TagTo communicate website events and track performance of advertisements
Facebook ImpressionsTo measure effectiveness of advertising.
Typekit by AdobeTo enable certain website features.
Google AnalyticsTo measure effectiveness of advertising and users’ interaction with content.
Yahoo AnalyticsTo measure effectiveness of advertising and users’ interaction with content.
Alexa MetricsTo measure effectiveness of advertising and users’ interaction with content.
New RelicSite analytics.
QuantcountTo tracking and log user actions for advertising purposes.
Facebook Connect To enable functionality with social media features.
RevContentTo tracking and log user actions for advertising purposes.
Google Publisher TagsTo tracking and log user actions for advertising purposes and managing ad operations.
PinterestTo enable functionality with social media features.
Facebook Social GraphTo enable functionality with social media features.
Twitter SyndicationTo enable functionality with social media features.
AddshoppersTo enable functionality with social media features.
Google Adwords ConversionTo measure effectiveness of advertising.
Facebook Custom AudienceTo tracking and log user actions for advertising purposes.
Google Tag ManagerTo manage cookies and tags on our website.
Twitter ButtonTo enable functionality with social media features.

Personal Data Transfers

If we transfer your personal data out of the European Economic Area (“EEA”) to countries not deemed by the European Commission to provide an adequate level of personal data protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal data, where required by EU data protection legislation:

  • Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer.
  • The EU – U.S. Privacy Shield Framework (for transfers to third parties in the United States that have self-certified to the Framework).

Please contact us if you want further information on the specific mechanism we have used to transfer your personal data.

Your Rights and Choices

The GDPR provides EU data subjects with certain rights regarding their personal data. Subject to certain conditions, you may ask Free Speech Systems to take the following actions in relation to your personal data that we hold:

  • Provide you with information about our processing of your personal data and give you access to your personal data.
  • Update or correct inaccuracies in your personal data.
  • Delete your personal data.
  • Transfer a machine-readable copy of your personal data to you or a third party of your choice.
  • Restrict the processing of your personal data.
  • Object to our processing of your personal data for direct marketing purposes.
  • Object to reliance on our legitimate interests as the basis for processing of your personal data.

You can submit privacy policy and notice requests by contacting us via our contact us page or our postal address provided below. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us via our contact us page or submit a complaint to the data protection regulator in your jurisdiction. You can find information about your data protection regulator here.

How to Contact Us

CVG Strategy can be contacted via our contact us via our contact us page or at the following address:

CVG Strategy, LLC

ATTN: PRIVACY INQUIRY

5445 Murrell Road, Suite 102-120

Viera, FL 32955

United States of America

CVG Strategy Privacy Policy

CVG Strategy Privacy Policy