Privacy Policy

Cordillera Applications Group

PRIVACY POLICY

December 7, 2020

INTRODUCTION

Cordillera Applications Group (“Cordillera”) understands the importance of respecting privacy and is committed to protecting your personal information. Cordillera prepared this Privacy Policy to inform you as to how we collect, process, and protect your personal information when visiting our website and learning about your privacy rights. It is important that you read this Privacy Policy to learn about the processing of your personal information by Cordillera.

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information that we may collect through your use of Applied Cordillera’s website referencing this Privacy Policy (the “Website”). It also applies to personal information about you that we collect because you are an employee, customer, or prospective customer of our products and services or that we are provided pursuant to a business relationship you have with us.

OUR CONTACT DETAILS

Name: Cordillera Applications Group, Inc.

Address: 999 18^th St, Suite 3000, Denver CO 80202

Phone: (303) 357-4606

Email: [email protected]

CONTROLLER

Cordillera’s Data Protection Officer is the controller for the personal information we process, unless otherwise stated. You may contact us by phone, email, and postal mail, see above.

Our Data Protection Officer (“DPO”) is Gordon Pendleton, Vice-President, Director, Cordillera Europe. You may contact him at [email protected] or via our postal mail address. Please mark the envelope “Data Protection Officer”.

2. THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

We currently collect and process the following information:

Identity Information includes your first name, maiden name, last name, username or similar identifier, marital status, title, job description, social security number, driver’s license, passport, employee number, date of birth, and gender;
Contact Information includes your billing address, delivery address, email address, telephone numbers, and home address;
Financial Information includes your bank accounts, credit and debit card numbers, and finance apps;
Transaction Information includes purchase orders, invoices, and payments to and from you;
Technical Information includes internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Information includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
Usage Information includes information about how you use our website, products and services; and
Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Information such as statistical or demographic information for any purpose. Aggregated Information may be derived from your Personal Information but is not considered Personal Information as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Information 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 information). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

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

Direct interactions. You may give us your Identity, Contact and Financial Information by filling in forms or by corresponding with us by postal mail, phone, email, or otherwise. This includes Personal Information you provide when you:

apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you; or
give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies. We may also receive Technical Information about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

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

(a) analytics providers such as Google;

(b) advertising networks;

(c) social media providers and similar platforms; and

(d) search information providers.

4. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your Personal Information when the applicable law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

Where we need to perform the contract, we are about to enter into, or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by [email protected].

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION

We have set out below, in a table format, a description of all the ways we plan to use your Personal Information

Purpose/Activity	Type of Information	Lawful Basis for Processing
To register you as a new customer.	(a) Identity (b) Contact.	Legitimate interest or consent.
To process and deliver your order including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications.	Legitimate interest.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications.	Legitimate interest or consent.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Your name, job title, phone number, employer, and any other information that you provide, usage, marketing and communications, and technical.	Legitimate interest.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Your name, job title, phone number, employer, and any other information that you provide, usage, marketing and communications, and technical.	Legitimate interest.
Whitepapers, research, and webinars. Newsletters and bulletins or updates on our products and services.	Your name, job title, phone number, employer, and any other information that you provide.	Consent or legitimate interest.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.	Technical, usage.	Consent or legitimate interest.
To make suggestions and recommendations to you about goods or services that may be of interest to you.	Name, email address, phone number, employer and job title, or any additional information you provide.	Consent or legitimate interest.
Phone.	Recording and details of your call, name, email address, phone number, gender, address, employer, job title and any other information you provide.	Consent or fulfilment of a contract or legitimate interest.
Email or social media correspondence.	Records of all information you provide in email or social media contact, including your: name, email address, phone number, gender, address, employer, job title, and any other information you provide/requested in the events registration form.	Consent or fulfilment of a contract or legitimate interest.
Information provided by you at events.	Name, email address, phone number, employer and job title, or any additional information you provide.	Consent or legitimate interest.
Provision of events or information services (including monitoring).	Name, address, email address, phone number, employer and job title.	Fulfilment of a contract.

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you registered for a promotion and/or service and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside Cordillera for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contacting us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable law

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties.
External Third Parties.
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 Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within Cordillera. This may involve transferring your data to the European Economic Area (EEA) and/or the United States of America (USA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.

Whenever we transfer your personal data out of the EEA, we will ensure to the extent reasonably possibly a similar degree of protection is afforded to it.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 unauthorised 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.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, relating to:

Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact the nominated DPO for further information.

NO FEE USUALLY REQUIRED

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.

WHAT WE MAY NEED FROM YOU

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.

TIME LIMIT TO RESPOND

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 several requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other affiliates of Cordillera acting as joint controllers or processors and who are based in various international locations.

EXTERNAL THIRD PARTIES

Service providers acting as processors

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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, at the time of 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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.

Changes to the Privacy Policy

Cordillera reserves the right to modify this Privacy Policy at any time, without prior notice, by posting the amended Privacy Policy on our website, so please review it frequently.

COOKIE POLICY

INFORMATION ABOUT OUR USE OF COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookie. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie: Twitter

Name: https://help.twitter.com/en/rules-and-policies/twitter-cookies

Purpose: This cookie is essential for our site to enables us to deliver targeted content and offers on various 3rd party platforms.

Cookie: Instagram

Name: https://help.instagram.com/1896641480634370?ref=ig

Purpose: We use cookies, pixels, local storage, and similar technologies to show you relevant content, improve your experience, and help protect Instagram and our users.

Cookie: LinkedIn

Name: https://www.linkedin.com/psettings/data-log

Cookie: Adobe Typekit

Name: https://fonts.adobe.com/about

Purpose: Necessary tracker, browsing, easy use in desktop applications or on the web, and typographic information.

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