Privacy and Confidentiality
While we do our utmost to protect the security and confidentiality of your personal information, the internet is not a secure place where privacy and confidentiality can be guaranteed. By accessing any Cotton Site, apps or other affiliated digital platforms, you acknowledge that your use of the Site, apps, or digital platforms may be subject to access or manipulation by, or disclosure to, third parties. Cotton is not responsible or liable for any damages that you or any other person may suffer in connection with any such violation of privacy, confidentiality or security.
What is Personal Information
Personal information is information about an identifiable individual, which includes information that can be used on its own or in combination with other information to identify, contact or locate a specific individual. Personal information does not include de-identified or aggregated information that cannot reasonably be associated with a specific individual, or any other information excluded by applicable law.
Types of Personal Information Collected by Us
The information that is collected varies by how you interact with us. Personal information that we collect may include:
- information such as name, company name, if applicable, contact information, account username and password;
- information you provide during interactions with us, whether online, by phone, in writing or otherwise, such as when you contact us or receive customer support, which information may include feedback, opinions and issues you may have encountered, comments that you post on our Site or digital platforms and your responses to surveys that you complete;
- information on how you use our Site, apps, other affiliated digital platforms or WiFi, including device and network activity, page interaction information and search terms, products or content you view/click on;
- social media account handles;
- demographic information and retailer preference; and
- other personal information with your consent or as permitted or required by applicable law,
We may also collect non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as statistical or aggregated information, to help us understand the interests of our customers, cardholders and users, to improve our Site, products and services, and to manage our risks and operations.
In addition to the foregoing, video surveillance may be used for safety and security reasons at our properties to monitor the public areas of those properties. If you do not want to have your images and/or images of your vehicle and license plate captures, please do not enter those areas.
Use of Personal Information Collected by Us
We will use your information to respond to you, regarding the reason you contacted us. In addition, personal information that we collect may be used to:
- To develop, enhance, improve, personalize or otherwise provide products, services or information.
- Make reference calls or request verification of your employment, history with prior employers or clients
- Respond to your questions, comments, inquiries or request for information regarding Cotton’s services
- Administering any loyalty or gift card programs
- To provide you with catalogs and emails about products, special offers, events or other news (more information regarding our use of your email address is provided below in the section regarding “E-Newsletters and other Electronic Communications”), if applicable
- To conduct and administer surveys and contests, sweepstakes and other promotions in which you have participated;
- Send you communications which you have opted-in to receive
- Accommodate special needs, e.g. during emergency evacuation
- Enforce rental agreement, parking agreement, lease and any other types of client agreements as applicable
- Create, maintain or administer your account, if applicable
- Tailor your experience on our Site, apps or other digital platforms
- Help diagnose technical problems with our Site and other digital platforms
- conducting market research and/or delivering tailored messages and targeted advertisements
- Tracking your usage of our Site, including transaction history and patterns
- Monitoring your use of our WiFi while within our properties
- Video surveillance, access cards and other information for general security purposes including prevention of potentially prohibited or illegal activities
- Performing functions required or authorized by law such as emergency or incident reporting including video, other surveillance for investigation, insurance and other risk management
- Employment purposes, including using resumes, and personal references provided in applications of employment and employment forms
- Communicate with you and administer your participation in surveys, events, programs, and promotions
- Protect our interests in a civil proceeding or a proceeding involving criminal activity, fraud, or misrepresentation
- Provide information related to a purchase, sale, reorganization, or financing of all or part of our business or operations, including for due diligence purposes in connection with any such proposed transactions
- Facilitating safety and security protocol
Sharing of Personal Information and Marketing
We may share your personal information:
- with our affiliates and subsidiaries for the purposes described in this policy;
- with business partners, contractors, service providers, and other third parties that support the operation of our business or assist us in providing our products and services, such as those that provide or assist with payment processing, identification and verification services, customer service, website hosting, information technology services, email delivery, data analysis, and other similar services, but only as necessary for such purposes. We require those third parties to keep your personal information confidential, to use it only for the purposes for which we disclose it to them, and to protect the personal information in a manner consistent with the standards set out in this policy and in accordance with applicable law;
- to comply with any subpoena, court order, lawful request, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
- to protect against, detect, suppress, investigate, and/or take action regarding suspected or actual financial abuse, fraud, or other harmful, unauthorized or illegal activity;
- in accordance with applicable law, in connection with, or during negotiation of, any merger, amalgamation, financing, securitization, or sale or other disposition of some or all of our business assets to another organization;
- to enforce our rights, including our terms and conditions that govern our products and services;
- to protect our property, or protect the rights, property or safety of you or others;
- for any other purpose disclosed by us when you provided the information;
- with your consent or as permitted or required by applicable law.
Other than as set out above, we will not share your information with any third party outside of our organization, other than as necessary to fulfill your request, e.g. information about an opportunity, nor will we sell or rent this information to anyone.
You will not receive any marketing or advertisements from Cotton or anyone else on our behalf at the email address you provide without your consent. We may, however, use the personal information that we gather to created targeted advertising such as through LinkedIn and Twitter.
We use web analytics tools on our Site and apps (Google Analytics and Adobe Analytics). Advertising tools are provided to us by advertising partners (like Google, Facebook, LinkedIn and Twitter). The information collected by these online tracking tools may be combined with your personal information if you have entered your access ID and password or provided it to us through your persistent cookie.
How to Opt Out of Targeted Advertising
You can choose not to allow your information to be used for targeted advertising by turning off personalized ads in the settings of Facebook, LinkedIn, or Twitter, turning off cookies, opting out of ads – users can also opt out of targeted advertising through “going incognito” or engaging private browsing on your web browser.
Cookies and other Data Collection
- details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site; and
- information about your device and internet connection, including your IP address, operating system, and browser type.
Cookies are small text files that websites send to your device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return and also help us provide a customized experience. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. You can change your browser settings to block cookies from being stored on your computer or mobile device. The ‘help’ menu of your browser should provide information on how to manage your cookie settings.
Links to other Websites
This Site contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
Storage of Personal information
We implement appropriate technical and organizational measures to ensure an appropriate level of security, keeping in mind the nature, scope, context and purpose of processing, cost, and the potential risk to you. We use industry standard technology and efforts to safeguard your personal data from loss, theft and unauthorized access, use or disclosure.
These include secure servers and firewalls. Physical access to those areas where information is gathered, processed or stored is restricted to authorized employees who require the information to perform a specific function.
Appropriate controls are in place over computer systems and data processing procedures and these controls are reviewed on an ongoing basis to ensure compliance with our security and privacy requirements. We require our service providers and agents to protect personal data processed on our behalf.
Subject to certain legal and contractual restrictions and reasonable notice, you may refuse or withdraw your consent to the collection, use or disclosure of your personal information at any time by contacting us as described below. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the implications to you at the time to help you with your decision.
In addition, if you wish to opt-out of marketing or promotional communications in the form of emails or text messages from us, you can opt-out by following the unsubscribe instructions included in any such message or by contacting us as described below. Please note that even if you opt-out of electronic marketing or promotional communications, we may still need to contact you with important transactional or administrative information about your account.
We may update or make changes to this policy from time to time. If we make any material changes, we will post the revised policy on the Site and we will update the effective date at the top of the policy. We may also notify you of changes by email, through a notice on the Site home page and/or any by other legal means. Please check the policy periodically for any updates or changes. Your continued use of the Site and/or our related products or services will be subject to the terms of the then-current policy.
Correct, Transfer or Delete Personal Data
Please notify us when there is a change in your personal data.