PRIVACY STATEMENT

Introduction

Your privacy is of the utmost importance to us and we want to be transparent about the personal data we collect, why we collect it, how we collect it, and how we share it. We also want you to understand your rights and choices regarding processing, access, correction, and deletion of personal data about you.

Who is CSG Services

CSG Services provides sales and marketing solutions to help our clients’ businesses sales and revenue growth and to help third parties learn about and decide to purchase our clients’ products and services.

CSG Services is a Washington Corporation with headquarters at 275 118th Ave SE, Bellevue, WA 98005.

How to contact us

CSG has appointed a data protection officer who is responsible for our compliance with relevant data protection legislation. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data protection officer using the details set out below.

By email: privacy@csgservices.com

Privacy information

This privacy notice applies to all members of CSG, subject to any variations due to local laws.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Data controller / Data processor

For most purposes, CSG Services is a data controller of any personal data that it obtains and processes. In certain circumstances, we may act as a data processor on behalf of our Client, in which case the privacy statements of the relevant Client will apply to any personal data that we process in the course of providing such services.

Clients / Prospects

In this privacy notice, we refer to our clients (whether they are incorporated organizations, partnerships, or any other organization) as Clients, and we refer to third party businesses (whether they are incorporated organizations, partnerships, or any other organization) who are interested in learning more about our Clients or who our Clients are interested in targeting as Prospects.

To whom does this Privacy Notice apply?

This privacy notice applies to:

  • Website Users: all individuals who visit our website at www.csgservices.com (or any other domain name registered in the name of CSG Services) (Website);
  • Individual Clients: all individuals who are or have been our individual Clients
  • Client contacts: all individuals who are our Client contacts where the individual is an employee, director or other representative of an organization which is or has been our Client;
  • Individual Prospects: all individuals who are or have been our individual Prospects
  • Prospect contacts: all individuals who are our Prospect contacts where the individual is an employee, director or other representative of an organization which is or has been a Prospect; or
  • Business contacts: all individuals who are our business contacts where the individual or the individual’s organization is a supplier or sub-contractor, supplies goods or services to us, provides professional services, has expressed an interest in us (including by contacting us by, telephone, e-mail, social media or other means) or has any other business relationship with us

Information about our Website

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

 

Protecting children’s privacy

Our Website is not intended for children and we do not knowingly collect any personal data relating to children. We do not intend for our products and services to be used, accessed or stored by children and we do not target children for marketing purposes.

If you are a parent or guardian and believe we may have collected information about a child, please contact our data protection officer at privacy@csgservices.com

About the personal data we collect and hold

Personal data, or personal information, means any information about an individual from which that person can be identified such as your name, telephone number, and email address.

Some CSG services may be co-branded and offered in conjunction with another company. If you register for or use such services, both CSG and the other company may receive information collected in conjunction with the co-branded services, and may use the information according to each company’s privacy statement and other agreements with you.

We do not collect any “special categories of personal data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

 

How is your personal data obtained?

We use different methods to collect personal data from and about you including through:

Direct interactions. You may give us your identity, contact, or similar personal data when you correspond with us by phone, e-mail, social media, live chat, via our Website or otherwise, including when:

  • you inquire about our products or services; or
  • you or your organization negotiate and/or enter into a contract or purchase order with us; or
  • you or your organization receive products or services from us;
  • you participate in or attend a webinar, seminar or event hosted or organized by us;
  • you respond to a questionnaire or survey; or
  • you give us some feedback.

Direct interactions with business contacts. You may give us your identity, contact and other business related personal data when you correspond with us, including when:

  • you or your organization negotiate and/or enter into a contract or purchase order with us; or
  • you or your organization provide services or products to us; or

Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • where you are a Client contact, Prospect contact or business contact, your organization or business may provide us with your identity, contact and employment data and we may receive information from third party references or from professional advisors.
  • we may obtain identity, contact and employment data from publicly available sources such as social media (e.g. LinkedIn, Facebook, Twitter), or other organizations’ websites.
  • we may obtain technical data (relating to the use of our Website) from analytics providers or search information providers.

Recording telephone calls and live chat sessions. We record incoming and outgoing telephone calls and live chat sessions, although we will always inform you of this during the call/chat session.

Marketing

With regard to marketing-related communications (whether by e-mail, telephone, post, social media or otherwise) and direct marketing activities, we differentiate between individual consumers and individuals who are representatives of a business or organization.

If you are an individual consumer (e.g. an individual Client, individual Prospect or individual business contact):

  • we will only provide you with direct marketing communications by e-mail where you have consented to receive such communications.
  • we may from time to time contact you email or by telephone with direct marketing communications where we feel that this may be relevant to you (based on services that we have previously provided to you) and you have not previously opted out of receiving such communications. When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.
  • you can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us on info@csgservices.com or by clicking “unsubscribe” at the bottom of any marketing e-mail.

If you represent another business (e.g. a Client contact, Prospect contact or corporate business contact):

  • we may from time to time contact you and provide you with direct marketing communications in any format (by e-mail, telephone, post, social media or otherwise) where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.
  • you can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us on info@csgservices.com .
  • you can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us on info@csgservices.com or by clicking “unsubscribe” at the bottom of any marketing e-mail.

Where you opt out of receiving these marketing-related communications, this opt-out will not apply to personal data provided to us for any other purpose.

With whom do we share your personal data?

For the purposes of providing our products and services to our Clients where we are acting as controllers, we may share information about our Client (and the relevant Client contacts) with Prospects and we may share information about Prospects (and the relevant Prospect contacts) with our Clients.

Where we are acting as a data processor on behalf of a Client, we may transfer personal data of Client contacts, Prospects and Prospect contacts to such Client or to a third party in accordance with instructions received from the relevant Client. In those circumstances, the privacy statement of the relevant Client will be applicable.

There may be other circumstances in which we may need to share your personal data with certain third parties (strictly on a confidential, business need-to-know basis), acting in our capacity as controllers. The third parties to which we may transfer your personal data include:

  • any member of CSG Services for the purposes of fulfillment of contracts with Clients, group restructuring, internal reporting, risk management, product/service diversification and compliance with this privacy notice
  • your business or organization, for the purpose of providing our services to your business or organization or receiving products or services from your business or organization, or working together with your business or organization.
  • service providers (acting as processors) who provide IT and system administration services, including cloud storage, a live chat facility and a webinar facility.
  • service providers (acting as processors) who provide data and marketing analysis services.
  • service providers (acting as processors) who provide event management services.
  • professional advisers including lawyers, bankers, accountants, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Any sharing of your personal data (where we are acting as controllers) will only take place either where you have provided your consent to such sharing, where we are legally obliged to do so, where it is necessary for the performance of a contract with you or where it is in our legitimate interests to do so, including as follows:

  • to perform a contract with our Clients;
  • to maintain network and information security;
  • to develop and improve our products and services in order to remain competitive;
  • to establish, protect and defend our legal rights;
  • to pursue our commercial objectives where this does not override your rights as a data subject.

Data security

CSG Services takes all reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorized access, modification or disclosure. The ways we do this include:

  • using encryption when collecting or transferring sensitive information
  • limiting physical access to our premises;
  • limiting access to the information we collect about you;
  • ensuring that we have appropriate security safeguards to keep personal information secure; and
  • where required by law, destroying or de-identifying Personal Information.

How long do we retain your personal data?

We use different methods to collect personal data from and about you including through:

We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your data will only be retained for as long as it is still required to provide you with services or is necessary for legal reasons.

Generally speaking, we will usually retain your personal data for six (6) months following expiration of any contracts or arrangements between us, unless we are obliged to retain your personal data for a longer period as a result of an overriding legal obligation or in order to establish, defend or exercise legal rights.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.

When we determine that personal data can no longer be retained (including where you exercise a right of erasure (see below for further details)), we ensure that this data is securely deleted or destroyed.

Your rights

With regard to any personal data that is processed CSG Services, you may:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, following your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to make a complaint at any time to an appropriate data protection supervisory authority, as set out below. We would, however, appreciate the chance to deal with your concerns so please contact us in the first instance on privacy@csgservices.com.

Changes to this privacy notice

We will occasionally update this Privacy Statement. If we make changes to this Privacy Statement or make any material changes to how we use your Personal Information, we will revise this Privacy Statement to reflect such changes and revise this Privacy Statement’s effective date We encourage you to periodically review this Privacy Statement to be informed of how we are using and protecting your Personal Information.

This version of our privacy notice was last updated on January 15th, 2019.

Contacting Us

If you would like to contact us for any reason regarding our privacy practices, please write to us at the following address:

CSG Services Corporation

Attn: Privacy

275 118th Ave SE Ste 115

Bellevue, WA 98005

USA

privacy@csgservices.com