Effective Date: October 1, 2022
This Privacy Policy (“Privacy Policy”) is published by CoreTrust Purchasing Group, LLC (referred to in this Privacy Policy as “CoreTrust,” “we” “us” or “our”) to explain our privacy practices for any information received via our website https://www.coretrustpg.com/ (“Website”) or tradeshows, conferences, or conventions (“Events”) (collectively, “Website & Events”).
By providing information for our Website & Events, you consent to the terms of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, including having your Personal Information used in any of the ways described in this Privacy Policy, do not provide us with your information. Please note, however, that if you do not provide us with your information, you may not be able to use or participate in certain features of our Website & Events.
- Changes and Updates to This Privacy Policy
We reserve the right to revise or update this Privacy Policy at any time, and you should periodically read the Privacy Policy to learn of any revisions or updates. We will notify you of any changes to the Privacy Policy by posting the revised or updated Privacy Policy and its “Effective Date” on this Website. Your providing information via the Website & Events thereafter constitutes your agreement to and acceptance of the Privacy Policy and its revisions or updates.
- Collection and Use of Your Personal Information
Collection Sources. Our Website & Events may permit you the opportunity to provide Us with Personal Information. As used in this Privacy Policy, “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual as defined by applicable laws. We may collect certain information, including Personal Information, from and about our users in various ways:
o directly from you or from your Employer on your behalf;
o automatically when you use our Website.
- Information Collected Directly from You or From Your Employers 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 employer on your behalf:
o Name
o Email
o Title
o Company
o Phone Number
- 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 device and usage information, such as your IP address
o browser and device characteristics
o operating system
o language preferences
o referring URLs
o device name
o country or location
o information, including preferences or characteristics, about how and when you use our Website o Internal automations/system settings
o “cookies” and other tracking technologies like pixel tags and web beacons, often called “smart cookies.”
Cookies and Other Tracking Technologies
Cookies are text files that are sent by servers to web browsers and stored on your computer. They tell us which parts of our Website you’ve visited so we can save your preferences for future visits to our Website. Web beacons and pixel tags are images embedded in a webpage or e-mail for the purpose of measuring and analyzing usage and activity. Some cookies and other technologies may serve to recall Personal Information previously provided by a user. Our Website, or third-party service providers acting on our behalf, may use cookies, web beacons, and pixel tags to help us analyze usage and improve our functionality.
We use information collected from cookies and other technologies to improve your user experience and the overall quality of our Website and connected GPO services. We use cookies to help us identify and track visitors, your usage of our Website, and your access preferences. We may use your Personal Information to see which web pages you visit our Website, which websites you visited before coming to our Website, and where you go after you leave our Website. We can then develop statistics that help us understand how our visitors use our Website and how to improve it. If you do not wish to have cookies placed on your computer, you should set your browsers to refuse cookies before using our Website. Please understand that if you do so, you may not be able to fully utilize our Website and therefore we disclaim, and you hereby waive, any claim or liability that may arise due to your partial or incomplete access to the content of any of our website as a result thereof.
GOOGLE ANALYTICS
We use Google Analytics cookies to help us to analyze traffic and understand how our customers use our Website. For more information on Google Analytics’ processing of Personal Information, please see http://www.google.com/policies/privacy/partners/. You may opt out of the use of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- Do Not Track Disclosure
Many web browsers include a Do-Not-Track (“DNT”) feature or setting that signals your preference not to have data about your online browsing activities monitored and collected. However, there is currently no uniform standard for recognizing and implementing the DNT signals. As such, we do not monitor or respond to Do Not Track browser requests. If a standard is adopted that we must follow in the future, then we will inform you about that practice in a revised version of this Privacy Policy.
- Contests
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.
- How We Use the Information Collected
We use the Personal Information we collect above to:
o provide access to the services you have requested
o respond to your questions and support you regarding the use of our Website & Events o communicate with you about our services
o comply with applicable law and legal requirements, including valid court orders
o design, improve, and administer our Website & Events
o analyze trends and statistics regarding use of our Website & Events and future service models o market our services to you
o protect against and prevent fraud, unauthorized transactions, claims, and other liabilities for any other purpose
- How We Disclose the Information We Collect
We share some information with service providers and partners who assist us in operating our Website & Events and connected GPO services and, in some cases, legal authorities.
o With our service providers and partners.
▪ We use third parties and vendors to help us operate and improve our Website & Events and connected GPO services. These third parties assist us with various tasks for business purposes, including website support and analytics. We do not allow these parties to use your information for any purpose other than to perform those services.
o Per your or your employer’s instructions.
▪ We may share and disclose Personal Information in accordance with a customer’s instructions and with appropriate consent, including any applicable terms in our Terms of Use and in compliance with applicable law and legal process.
o Other situations. We also may use and disclose information outside of our day-to-day business practices and in ways unrelated to our Website & Events.
▪ In the Event of Merger, Sale, Divestiture, or Change of Control. We may transfer or assign Personal Information to an entity that acquires all or substantially all of our assets or stock whether by merger, acquisition, reorganization, or otherwise.
▪ Other Disclosures. We may disclose Personal Information about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process, or governmental request; (ii) enforce our Terms of Use or Terms of Sale, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to our, your, or third parties’ rights, property, or safety.
We do not sell your Personal Information for monetary or other valuable consideration.
9. Your Choices About Your Information
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 Website & Events or connected GPO services.
9.1. Marketing. If you have supplied your email address in relation to our Website & Events, 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.
9.2. Advertisements. Advertisements appearing on any of our Website may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by us and does not cover the use of cookies by any advertisers.
9.2.1. 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 interest based 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/
- Third Party Links. Our Website may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us—and which may link to other websites, services, or applications. Please be aware that we are not responsible for the privacy or practices of other websites or third parties. We do not make any guarantee regarding those third-party websites, services, or applications, and we are not liable for any loss or damage caused by the use of such sites. Any data collected by third parties is not covered by this Privacy Policy. You should review the policies of the third parties and contact them directly if you have any questions about their services or practices.
- 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.
- 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 Website & Events, 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.
- Children. We do not knowingly collect or solicit personal information from children under the age of 18. By providing information via the Website & Events, you represent that you are at least 18 years old. If you are under 18, please do not provide information via our Website & Events. 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.”
- California Privacy Policy. This section applies solely to California residents (“consumers” or “you”) from whom we receive Personal Information via our website https://www.coretrustpg.com/ (“Website”) or tradeshows, conferences, or conventions (“Events”) (collectively, “Website & Events”). This section uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and any subsequent amendments or acts, including but not limited to the California Privacy Rights Act (“CCPA”), including “Personal Information,” which is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
14.1. Collection & Sharing of Personal Information. During the 12-month period prior to the effective date of this Privacy Policy, we may have shared or disclosed the following categories of Personal Information about
you for a business or commercial purpose with certain categories of third parties, as described below. For more information on how we disclose Personal Information, please see CoreTrust’s Privacy Policy section on “How We Disclose the Information We Collect.” We do not sell your Personal Information in exchange for monetary consideration and have not done so during the preceding 12 months.
| Categories of
Personal Information Sold, Shared, or Disclosed |
Personal
Information Collected |
Source of
Personal Information Collected |
Categories of Third Parties to Whom
Personal Information Was Sold, Shared, or Disclosed |
Business or Commercial Purpose of Selling,
Sharing, or Disclosing Personal Information |
| Identifiers | real name, email address, internet protocol (IP)
address, cookies, beacons, and mobile ad identifiers |
Directly from you or from
your Employer on your behalf; automatically when you use our Website. |
Service Providers | • Verify consumer’s
identity • Provide customer service regarding products and features • Support our internal and business operations • Fulfill a consumer’s request |
| Additional
Information Subject to Cal. Civ. Code § 1798.80 |
real name | Directly from you or from
your Employer on your behalf |
Service Providers | • Verify
consumer’s identity • Provide customer service regarding products and features • Support our internal and business operations • Fulfill a consumer’s request |
| Internet or Other Electronic
Information Activity |
IP address,
browsing history, search history, information regarding a consumer’s interaction with our website, applications, or |
Automatically when you use our Website. | Service Providers | • Enable
consumer to request information or purchase a product from our services. • Support our internal and |
| advertisements, cookies, beacons, mobile ad
identifiers, clickstream, time or date electronic communication was created, sent, or received |
business
operations • Fulfill a consumer’s request |
14.2. California Consumer Privacy Rights
14.2.1. Shine the Light Law. Under California’s “Shine the Light” law, 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 “Shine the Light.”
14.2.2. Consumer Rights Under CCPA. 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:
o The categories of Personal Information that we collected about you;
o The categories of sources from which the Personal Information is collected;
o 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
o 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: Unless proper consent is acquired, a business shall not sell or share the personal information of consumers if the business has actual knowledge that the consumer is less than 16 years of age. We do not have actual knowledge that we collect, share, or sell the Personal Information of minors under the age of 16.
- 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, as defined by California privacy laws, which 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 rights, please refer to the below Section “Consumer Requests.”
14.3. Consumer Requests. You may exercise your consumer rights by contacting us as described in the Contact Us section below.
14.3.1. Right to Non-Discrimination. We may not discriminate against you because you exercise any of your rights, including, but not limited to:
o Denying goods or services to you;
o Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
o Providing a different level or quality of goods or services to you; or
o Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
14.3.2. Verifying Requests. CCPA requires us to verify your identity when you make a consumer request to help protect your privacy and maintain security. If you request access to or deletion of your Personal Information, we may require you to provide additional information, including but not limited to: name, email address, telephone number, or company. When you make such a request, we will respond within the time frames legally required and provide an explanation for any denials of requests.
14.3.3. 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:
o The authorized agent to provide proof that you gave written permission to the authorized agent to submit the request;
o You to verify your identity directly with us; or
o You to directly confirm with us that you provided the authorized agent permission to submit the request.
15. Contact Us. If you have any questions or concerns about this Privacy Policy or the information practices of our Website & Events, please contact us at privacy@CoreTrust.com or by calling us toll-free at 855-208-2362.