Personal Data We Collect Provided Directly by You or by Third Parties. We collect Personal Data that you provide to us when you register for an account, update or change information on your account, use our services, send e-mail messages, and/or participate in other services on our Site. During registration and later on our platform, we may collect Personal Data such as your real name, alias, e-mail address, phone number, postal address, current or past job history, unique personal identifier, online identifier, Internet Protocol address, account name, payment account information, Social Security number, driver’s license number, or other similar information. We may also create Personal Data about you, such as records of your interactions with us, our clients, or our Experts, or from third parties that provide us with it or access to it.
How We Use Your Personal Data. We may use your Personal Data for various purposes, subject to applicable law, including to:
Allow you to access and use the Site and to provide or facilitate your participation in certain information, products, or services that you request from us;
Operate, manage, and communicate with you via our Site;
Notify you of changes to our Site or services;
Monitor, improve, and develop our services;
Facilitate communications or transactions with you;
Share it with other parties as necessary in order for us to facilitate your participation in our services (e.g., cloud service providers, payment processors, etc.).
How We May Share Personal Data. We may, for legitimate business purposes, disclose your Personal Data to other parties, including:
Your appointed representatives;
Other Coleman entities;
Professional advisors to Coleman, such as accountants, auditors, and lawyers, and
Other parties as necessary in order for us to provide you with our services (e.g., cloud service providers, payment processors, etc.).
We may disclose your personal data to a third party if we believe in good faith that such disclosure is necessary or desirable (i) to comply with lawful requests, subpoenas, search warrants, or orders by public authorities, including to meet national security or law enforcement requirements, (ii) to address a violation of the law, (iii) to protect the rights, property, or safety of Coleman, its users or the public, or (iv) to allow Coleman to exercise its legal rights or respond to a legal claim.
If we engage a third party to process your Personal Data, that party will (i) only process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.
For Residents of the European Economic Area (EEA) Only:
Legal Basis for Data Processing. As explained above, we use your Personal Data in various ways depending on your use of the Site and/or participation in Coleman’s services. We may process your Personal Data in reliance upon one or more of the following legal bases, depending on the circumstances: (1) with your consent; (2) as necessary to perform our agreement to provide services; (3) where required by applicable law; (4) where necessary to protect the vital interests of any individuals; or (5) where we have a legitimate interest.
Transfers of Personal Data. Personal Data we collect may be transferred to, and stored and processed in, the United States or any other country in which we, our affiliates, or third parties with whom we engage in order to provide our services maintain facilities. We will ensure that transfers of Personal Data to a third country or an international organization are subject to appropriate safeguard as described in Article 46 of the General Data Protection Regulation.
Right to Access and Correct Personal Data. You can access your Personal Data and confirm that it remains correct and current by logging into the Site. You have the right to request access to your Personal Data and to receive a copy of your Personal Data, as well as certain information about our processing activities with respect to your Personal Data. You have the right to request correction or completion of your Personal Data if it is inaccurate or incomplete. You have the right to restrict our processing if you contest the accuracy of the data we hold about you, for as long as it takes to verify its accuracy. If you are a current Coleman client or a current member of our expert network and would like a copy of your Personal Data, please log in to the Site and click on the ‘Personal Data’ link at the bottom of the page and follow the instructions (if you are not a current Coleman client or a current member of Coleman’s expert network and would like a copy of your Personal Data, please send an e-mail to: firstname.lastname@example.org).
Right to Personal Data Portability. Where technically feasible, you can request that your Personal Data be transmitted directly from Coleman to another data controller in a structured, commonly used, and machine-readable format. If you would like to request your Personal Data to be ported, please log in to the Site and click on the ‘Personal Data’ link at the bottom of the page and follow the instructions. If you are not a current Coleman client or a current member of Coleman’s expert network and would like a copy of your Personal Data, please send an e-mail to: email@example.com.
Right to Request Data Erasure. You have the right to have your data erased from our Site if (i) the data is no longer necessary for the purpose for which it was collected, (ii) you withdraw consent and no other legal basis for processing exists, or (iii) you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing. Your Personal Data will generally be erased from the Site without undue delay and will be anonymized in order to be able, if necessary, to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms and Conditions or agreements, or fulfill your request to “unsubscribe” from further messages from us. If you would like to request the erasure of your Personal Data from our Site, please log in to the Site, and click on the ‘Personal Data’ link at the bottom of the page and follow the instructions.
Right to Withdraw Consent. Where we process your Personal Data on the basis of your consent, you have the right to withdraw consent. If you would like to withdraw your consent to the processing of your Personal Data, please send an e-mail to: firstname.lastname@example.org.
Information We Collect. Our Site collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). Coleman’s Site has collected the following categories of personal information from its consumers within the last twelve (12) months:
Coleman obtains the categories of personal information listed above from the following categories of sources:
Information collected directly from consumers through use or participation in Coleman’s services,
Subscription databases and information vendors.
Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Use of Personal Information. In addition to the stated uses set forth above, we may use, or disclose the personal information we collect for any purpose described to you when collecting your personal information or as otherwise set forth in the CCPA.
Sharing of Personal Information. Coleman may disclose your personal information to third parties for purposes consistent with the business purpose for which it was collected. In the preceding twelve (12) months, Coleman has disclosed the following categories of personal information for a business purpose:
California Customer Records personal information categories.
Professional or employment-related information.
Sale of Personal Information. In the preceding rolling twelve (12) months, Coleman has not sold personal information.
Your Rights and Choices Related to Personal Information. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights. You have the right to request that Coleman disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights for Personal Information. You have the right to request that Coleman delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Request Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination.We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.