Privacy Policy

 

Effective Date: January 1, 2023

Last Updated: January 1, 2023

 

Introduction

 

Collateral Specialists, Inc., a Delaware corporation (collectively referred to herein as “CSI”, “we”, “our” or “us”), recognizes the importance of protecting personal data we may collect from any individual or entity (“Users”, “you”, or “your”) who visit our website and who use our mobile application (“App”). This Privacy Policy applies to data collection by CSI and shall apply to your use of the website, www.csina.com and the CSI App (“Services”).

 

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Services, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services.

 

  1. When this Privacy Policy Applies

 

Our Privacy Policy applies to all of the Services offered by CSI.  Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

 

  1. Information We Collect

 

We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.

 

When you use our Services, we collect Personal Data in the following ways:

 

  • Information You Give to Us

 

Certain information is required when creating an account to use our Services on the mobile application, such as your name, email address and password. 

 

  • Information We Obtain from Your Use of Our Services

 

We collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on your mobile device. When you use our App, we automatically collect and store this information in service logs. This includes: details of how you used our App; internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited.  We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.  

 

If you grant us access to your location, CSI may collect information about your location when you use our Services and Services. Your location can be determined by: GPS, IP address, and information about things near your device, such as Wi-Fi access points and cell towers.  If you enable location services for our mobile application, we may collect location data periodically as you use or leave open our App.

 

When using our Services, we or our service provider may collect your unique device ID. We may use such information for internal purposes and to provide you a better experience, such as to troubleshoot application problems you may experience.

 

  • Cookies and Similar Technologies

 

We use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device.

 

  1. How We Use Information We Collect

 

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

 

  • To present, operate or improve the App and Services, including analysis of App activity;
  • To authorize access to our Services and Services;
  • To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
  • To personalize the Services to your goals;
  • To customize or tailor your experience of the Services, which may include sending customized messages;
  • To improve our App and Services;
  • To secure our Services, including to authenticate Users;
  • To respond to and support Users regarding their use of the Services and Services;
  • To comply with all applicable legal requirements;
  • To enforce this policy and other agreements;
  • To perform data analysis and testing;
  • To investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm our Users;
  • To resolve disputes;
  • To otherwise fulfill the purpose for which the information was provided.

 

We use the information we collect from our Services to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.

 

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

 

  1. Our Legal Basis for Collecting Personal Data

 

Whenever we collect Personal Data from you, we may do so on the following legal bases:

 

  • Your consent to such collection and use;

 

  • Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;

 

  • Our legitimate business interest.

 

  1. Information We Share

 

We do not share Personal Data with companies, organizations and individuals outside of CSI unless one of the following circumstances applies:

 

  • With Your Consent. We will share Personal Data with companies, organizations or individuals outside of CSI when we have your consent to do so.

 

  • For External Processing. We may provide Personal Data to trusted third parties including contractors that process transactions. It is our policy to only share Personal Data with contractors, service providers, and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.

 

  • For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of CSI if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, including investigation of potential violations, detect, prevent, or otherwise address fraud, security or technical issues., or protect against harm to the rights, property or safety of CSI, our Users or the public as required or permitted by law.

 

  • Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our Users is often a transferred business asset. In the event that CSI itself or substantially all of our assets are acquired, Personal Data about our Users may be one of the transferred assets.

 

  • Non-Personal and Aggregate App Use Information. CSI may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such De-Identified Information publicly and to third parties, for example, in public reports about exercise and activity, or to CSI Partners under agreement with us. 

 

  1. Your Failure to Provide Personal Data

 

Your provision of Personal Data is required in order to use certain parts of our services and our programs.  If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs. 

  1. Our Retention of Your Personal Data

 

We may retain your Personal Data for a period of time consistent with the original purpose for collection.  For example, we keep your Personal Data for no longer than reasonably necessary for your use of our App and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

 

We retain your Personal Data even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

 

  1. Your Choices and Accessing, Updating or Deleting Your Personal Data

 

Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that Personal Data we have about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

 

  1. Third Party Links

 

The Services may contain links to web pages operated by parties other than CSI. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. CSI strongly recommends that each User review the third party’s terms and policies.

 

  1. How We Protect Personal Data

 

CSI maintains administrative, technical and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.  We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.  

 

  1. Children

 

Neither the Website nor the App is intended for use by children under the age of 13. 

 

  1. Direct Marketing and “Do Not Track” Signals

 

CSI does not respond to Do Not Track (DNT) signals.

 

  1. Changes to this Privacy Policy

 

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

 

  1. How to Contact Us

 

If you have any specific questions about this Privacy Policy, you can contact us via email or phone or by writing to us at the address below:

 

Send email to: info@csina.com

Call:                415-883-5700

 

Send mail to our address:

 

Collateral Specialists, Inc.

Attn: Privacy Policy Inquiry

1670 Corporate Circle, Suite 200

Petaluma, CA 94954