Effective Date: October 1, 2022
- Collection and Use of Your Personal Information
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 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
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
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.
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.
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.
9.2.1. 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/
- 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.”
Information Sold, Shared, or
|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
|Directly from you or from
your Employer on your
automatically when you use our Website.
|Service Providers||• Verify consumer’s
• Support our
• Fulfill a
Subject to Cal. Civ. Code § 1798.80
|real name||Directly from you or from
your Employer on your behalf
|Service Providers||• Verify
• Support our
• Fulfill a
|Internet or Other Electronic
browsing history, search history,
interaction with our website,
|Automatically when you use our Website.||Service Providers||• Enable
• Support our
|advertisements, cookies, beacons, mobile ad
clickstream, time or date electronic communication
was created, sent, or received
• Fulfill a
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.