Last Modified Date: August 2023
2. COLLECTION OF PERSONAL INFORMATION
The Services may permit you the opportunity to provide us with Personal Information. We may collect certain information, including Personal Information, from and about you in various ways, including:
- directly from you or from your authorized agent on your behalf;
- directly when you use the Platform; and
- automatically when you use our Website.
a. Information Collected Directly from You or From Your Authorized Agent on Your Behalf
Either from filling out an online contact form or providing information at Events, we may collect the following Personal Information directly from you or from your authorized agent, such as your employer, portfolio company, or private equity firm, on your behalf:
o Contact Information, including name, email, title, company, and phone number
b. Information Collected Directly from You When You Use the Platform
We may collect the following Personal Information directly from you when you use the Platform:
c. Information Automatically Collected When You Use Our Website
We may automatically collect data about you when you use our Website. This information is primarily used to maintain the security and operation of our Website, and for our internal analytics in connection with our GPO services. This information may include:
o Internet and Electronic Activity, including device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country or location, information, including preferences or characteristics, about how and when you use our Website
o Third Party Cookies
▪ Google Analytics, visitors to the Website may be tracked using Google Analytics. The Personal Information collected by Google Analytics is primarily used to optimize the Website for users; however, we may also use this data for marketing purposes. The Personal Information we automatically collect using Google Analytics is shared with Google. For more information on Google’s Privacy Policies, visit: https://policies.google.com/privacy. You can also optout of having your personal data used by Google Analytics by following the instructions located at https://tools.google.com/dlpage/gaoptout/. Without limitation, Google Analytics may collect the following types of data from users of the Website:
- Type of web browser used, software manufacture and version number.
- Type of operating system
- Color processing ability of the users screen
- Flash version
- Screen resolution
- Network location and IP address
- Country, city, state, region, county, or any other geographic data
- Bandwidth (internet connection speed)
- Time of visit
- Pages visited
- Time spent on each page of the Website
- Referring site statistics
- The website the user came through in order to arrive at the Website
- Search engine query used
3. PURPOSE OF COLLECTION
- Provide the Services. We may use your Personal Information to provide the Services, and any other services you may request from us.
- Monitor the Website. We collect your Personal Information for monitoring purposes to help us diagnose problems with our servers, administer and troubleshoot the Website, calculate usage levels, analyze industry standards, and analyze transactions, trends, and statistics regarding the use of the Website.
- Respond to Inquiries and Fulfill Requests. We may use your Personal Information to respond to your inquiries and to fulfill your requests for information.
- Communicate with You. We may use your Personal Information to communicate with you about Events, the Services, newsletters, and other items that may be of interest to you. We may also contact you on behalf of our third-party business partners about a particular offering of theirs that may be of interest to you.
- Improve the Services. We may use your Personal Information to make the Services more stable and user-friendly, to analyze service issues, improve the design and content of the Services, personalize your experience, analyze how the Services are used, offer new services, and to develop new marketing programs relating to the Services.
- Support Business Operations. We may use your Personal Information to support our internal and business operations, including marketing, security, and advertising.
4. DISCLOSURE OF PERSONAL INFORMATION
- Subsidiaries and Affiliates. We may disclose Personal Information about you to our subsidiaries and affiliates.
- CoreTrust Vendors. We may disclose your Personal Information to vendors of CoreTrust, subject to your or your company’s Participation Agreement.
- Marketing Partners. We may share your Personal Information with entities that perform marketing or data aggregation services on our behalf, or with which we or an affiliate has joint marketing arrangements. We may also share your Personal Information with our marketing partners for marketing and promotional purposes.
- Advertising Partners. We may share your Personal Information with third party advertising partners, including but not limited to Google Display Advertising and Remarketing services. These advertising partners may use first- and third-party cookies together to inform, optimize, and serve ads based on your past visits to the Services. You can opt out of these services using the Ads Preferences Manager or you can use the Google Analytics opt-out browser add-on. These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks, commonly referred to as “interest-based advertising.”
- Analytics Partners. We may use analytics-based technologies to assist with personalization, advertising, and marketing. These technologies capture how you interact with the Services through behavioral metrics, heatmaps, and session replay to improve and market our products and Services.
- Authorized Representatives. If another individual or entity is managing or associated to your account with us or your email account which the Services connect to on your behalf (for example, a company manager controlling access to a company account), as authorized by you or as a personal representative under applicable law, that person can view all Personal Information about you on the Services.
- In the Event of Merger, Sale, Divestitures, or Change of Control. CoreTrust reserves the right to transfer Personal Information to a buyer or other successor in interest that acquires rights to that information as a result of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of CoreTrust or substantially all of its assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about you is among the assets transferred.
- With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction.
You have choices about how we use your information. Please understand that if you choose not to disclose information to us, it may affect your ability to use some features of our Services or connected GPO services.
a. Marketing. If you have supplied your email address in relation to our Services, we may further send you emails or notifications via the membership portal to provide you with information, to inform you of new events or content, to solicit your feedback, or to keep you up to date on us. You can opt out of our marketing and promotional communications at any time by clicking Unsubscribe or otherwise following the opt out prompts on these communications. You also may ask us not to send you other marketing communications by contacting us as specified in the “Contact Us” section below, and we will honor your request. Please note that even after you are removed from our marketing lists, we may still send you non promotional communications, such as responding to service requests.
We and our service providers may use information about your interactions with our Website to predict your interests and select the ads you see on and off our Website. This is known as interestbased advertising. In providing interest-based ads, we follow the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance (“DAA”). For more information about interest-based advertising and how you can opt out, visit:
- Digital Advertising Alliance: http://www.aboutads.info/choices/
- Network Advertising Initiative: http://www.networkadvertising.org/choices/
6. THIRD PARTY LINKS
7. CONFIDENTIALITY & SECURITY
CoreTrust values your privacy and is committed to protecting your information. We have appropriate administrative, technical, and physical safeguards in place to ensure the integrity and security of your information. We undertake commercially reasonable efforts to guard against unauthorized access, use, alteration, or destruction of Personal Information.
8. INFORMATION RETENTION
We keep your personal data only as long as necessary to provide you with our services and for legitimate and essential business purposes, such as maintaining the performance of our Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal information for as long as you are a registered member of our services.
We do not knowingly collect or solicit personal information from children under the age of 18. By providing information via the Services, you represent that you are at least 18 years old. If you are under 18, please do not provide information via our Services. If we become aware that we have inadvertently received or collected Personal Information from a child who is under the age of 18, we will attempt to immediately delete that information from our files and records. If you believe a child who is under the age of 18 has provided us with Personal Information, please contact us at the address listed below in “Contact Us.”
We occasionally offer contests via our Website or in-person at Events. To participate in these contests, we may require you to provide us with Personal Information, such as your name, company, title, email address, and phone number. We will use the information you provide us for purposes including administering the contest and other purposes disclosed in contest rules and policy. We do not sell any Personal Information provided to us. If you have any questions or concerns, please contact us via the Contact Us section below.
10. CALIFORNIA PRIVACY RIGHTS
This section explains how we collect, use, and disclose Personal Information about users, customers, and visitors who reside in California (“consumers” or “you”). It also explains certain rights afforded to consumers under California’s Shine the Light law and the California Consumer Privacy Act of 2018 (“CCPA”), as revised and updated by the California Privacy Rights Act (“CPRA”). This section uses certain terms that have the meaning given to them in the CCPA including Personal Information.
a. Shine the Light
Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the Contact Us section below with a reference to California Disclosure Information.
b. Categories, Purpose, & Sources of Personal Information Collected
c. Selling and Sharing Personal Information
We do not sell or share your Personal Information in exchange for monetary consideration; however, we may use tools described above such as Google Analytics, which may be interpreted as sharing your Personal Information. As such, please see the above Personal Data Automatically Collected and Choices sections for more information regarding opting out of use of these tools.
|Categories of Personal Information that May Be Sold, Shared, or
|Categories of Third Parties to whom Personal Information May Be Sold, Shared, or Disclosed||Business or Commercial Purpose of Selling, Sharing, or Disclosing Personal Information|
|Internet or Other Electronic Network
d. California Consumer Privacy Rights
Under CCPA, consumers have certain rights regarding their Personal Information, as described below.
- Right of Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
- The categories of Personal Information that we collected about you; o The categories of sources from which the Personal Information is collected;
- The business or commercial purpose for collecting or selling Personal Information; o The categories of third parties with whom we share Personal Information; o The specific pieces of Personal Information that we have collected about you; o The categories of Personal Information that we disclosed about you for a business purpose or sold to third-parties; and
- For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
- Right of Deletion: You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.
- Right to Opt-Out: You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration. However, we do not sell any Personal Information.
- Right to Opt-In: We do not have actual knowledge that we collect, share, or sell the Personal Information of minors under the age of 18.
- Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed for “the purpose of inferring characteristics about a consumer.” However, we do not collect or process Sensitive Personal Information for this purpose.
- Right to Correction: You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.
If you would like to exercise your California privacy rights, please refer to the Consumer Requests and Verification section below.
11. CONSUMER REQUESTS AND VERIFICATION
a. Right to Non-Discrimination
- Denying goods or services to you;
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing a different level or quality of goods or services to you; or
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
b. Verifying Requests
You may request to exercise your rights of access, deletion, or correction by contacting us as described in the Contact Us section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request. If you request access to or deletion of your Personal Data, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address. When you make such a request, you can expect the following:
- As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
- We will confirm that you want your information accessed, corrected, and/or deleted.
- We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.
- We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
- In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Site or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.
c. Authorized Agents
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the Contact Us section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:
- The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
- You to verify your identity directly with us; or
- You to directly confirm with us that you provided the authorized agent permission to submit the request.
12. CONTACT US