C&L International LLC
- DATA WE COLLECT AND HOW WE USE IT
We collect the personal information you voluntarily provide to us, which includes your name and e-mail address, in order to subscribe to our newsletter, receive our content, comment on our blog, and/or purchase services or online products. There is also other personal data we may collect detailed herein.
We collect data from you directly when you fill out a form, purchase a product, or communicate with us via email or social media. We also collect data from you when you use our Website. We may collect personal data from third parties such as our payment processors, advertising networks, and/or analytics providers. Your data is stored in a secure platform. We use your personal data for processing as outlined below or a reasonably compatible purpose.
- Usage Data. We may process data about your use of our Website and services. This may include your IP address, browser type, operating system, geographical location, page views, website navigation paths, and frequency and/or pattern of your use of our website. This data is collected through our analytics tracking systems, including GOOGLE ANALYTICS. This data is used to analyze the use of our Website, to deliver relevant content and advertising, and understand our users. The legal basis for processing is our legitimate interest, namely monitoring and improving our website, marketing, and services.
- Customer Data. We may process user data, such as name, email address, address, telephone, credit-card number, and other relevant data as related to purchases of our products and/or services. We process this data to supply products and/or services to you, as well as to market other relevant goods and services to you. The legal basis for processing is consent and your affirmative action to enter into such contract with us and/or the purchase and delivery of the contract between you and us.
- User Data. We may process personal information you provide us for the purpose of subscribing to our email notifications, free content, and/or newsletters, as well as communication data that you send to us either through email, social media, or other posting and/or communication methods. We process this data for the purposes of communicating with you, to deliver relevant website content, and for the purposes of sending you marketing, content and/or emails. The legal basis for this process is consent or our legitimate interests, which is to grow our business and keep records which may be needed to pursue or defend a legal action.
- MARKETING AND ADVERTISING.
The above Data may be used to send you marketing communications about our business or products. The legal basis for this type of processing is either consent or our legitimate interests in growing our business. We may send you such communications if you requested it and/or if you agreed to receive such communications. You may opt-out of such communications at any time through the ‘unsubscribe’ button in each email or contacting us at sales(at)thefbabroker(dot)com.
Any of the above Data may be used to deliver advertisements to you, including Facebook Ads, Instagram, and/or other similar advertisements. We may also use such Data to understand the effectiveness of our advertising. The legal basis for this type of processing is our legitimate interest to grow our business through marketing and advertising.
- SHARING YOUR PERSONAL DATA
We do share your information with trusted third parties who provide support in running this Website including any blog or newsletter, as well as those parties and services that help administer our business. Your data will never be shared with unrelated third parties. We may disclose your information to payment service providers, administrative and marketing providers, business advisors, or third parties if we sell or transfer parts of our Company. Third parties we share your data with will keep it secure and respect your privacy under the law. We take steps to ensure these companies comply with the GDPR.
- ANTI-SPAM POLICY
The term “cookies” refers to small pieces of information that a website sends to your computer’s hard drive while you are viewing the Site. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). You have the ability to accept or decline cookies and tracking signals using your web browser settings. If you choose to disable cookies, some areas of the Website may not work properly or at all. Our Site may not respond to Do Not Track signals sent by your browser.
- THIRD PARTY LINKS.
- DATA SECURITY AND BREACH RESPONSE
We do our best to protect your information for any unauthorized access, misuse, or disclosure. We may allow access to your personal data to our employees, contractors, and service providers that need to know such data to perform necessary business services. Personal data will be kept confidential and employees and/or contractors will only have access to it when necessary. LastPass will be used to manage data access when possible.
Should there be a potential breach of personal data, we have procedures in place to respond. The breach will be identified, the scope will be determined, and we will make reports and/or notification if we are legally required to do so.
You acknowledge that the personal information you voluntarily share could be accessed or tampered with by a third party. You agree that we are not responsible for any intercepted information shared through our Site without our knowledge or permission. Additionally, you release us from any and all claims arising out of or related to the use of such intercepted information in any unauthorized manner. You agree to notify us for any breach of security or unauthorized use of your information.
- DATA RETENTION AND DESTRUCTION
Personal data that we process for any purpose shall not be kept for longer than is necessary to fulfil its collection purpose or to satisfy a legal or accounting purpose. In some cases, your data by be anonymized for research purposes and used indefinitely. If your data no longer meets any of the above criteria, personal data will be deleted or otherwise disposed of in a safe and secure manner.
- INTERNATIONAL TRANSFERS
Your data may be transferred to other countries and by using the Website, you consent to the transfer of information to countries outside your country of residence. If you are located in the European Union, we may store and share your personal data with companies located outside of the European Economic Area. We will always do our best to ensure security of your data. We aim to use US-based providers that are part of the EU-US Privacy Shield. You may always request information on how and where your data is processed and stored.
- CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
We do not knowingly collect or solicit data online from or market online to children under the age of 13 in compliance with the Children’s Online Privacy Protection Act (COPPA).
- CHANGES TO THIS POLICY
- YOUR RIGHTS
Your rights under data protection laws include the right to access, erase, correct, restrict, and/or object to our use and processing of your personal data, as well as the right to portability of the data. You have the right to confirmation as to how and where we process your data. To the extent that the legal basis for our processing consent, you have the right to withdraw at any time. If you consider our processing to infringe data protection laws, you have the right to lodge a complaint with a supervisory authority.
- OUR INFORMATION
This Website is owned and operated by:
C&L INTERNATIONAL LLC
690 S HIGHWAY 89, SUITE 200,
JACKSON, WYOMING 83002
Updated: 2 July, 2020
For California Residents
Information We Collect
Our Websites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Websites have collected the following categories of personal information from its consumers within the last twelve (12) months:
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
C. Protected classification characteristics under California or federal law.
D. Commercial information.
E. Biometric information.
F. Internet or other similar network activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
K. Inferences drawn from other personal information.
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
The Site obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete on our site.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to send us an email or sign up for our mailing list, we will use that personal information to respond to your inquiry.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
The Site will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
The Site may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Service providers.
- Data aggregators.
Sales of Personal Information
In the preceding twelve (12) months, we have not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that the Site disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that the Site delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at sales(at)thefbabroker(dot)com.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to sales(at)thefbabroker(dot)com.