Privacy Policy
Effective Date: August 2023
Privacy Policy
This Privacy Policy describes how Zephyr, Inc. and its affiliates (collectively, “Zephyr,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information when you visit our website available at https://cfacservice.com/ (the “Site”), use our services, apply for a job with us, and through any other websites, pages, features, or content owned and operated by us that direct to this Privacy Policy (collectively, the “Services”). This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.
You can jump to particular topics by going to the headings below:
How We Protect and Retain Information
Transmission Of Information To Other Countries
Third-Party Applications/Websites
Personal Information We Collect
“Personal information,” as used in this Privacy Policy, generally is any information that identifies or relates to an individual identifiable. The specific definition of personal information depends on the applicable law based on your physical residence. Only the definition that applies to your physical residence will apply to you under this Privacy Policy. We collect personal information about you in potentially different ways depending on how you interact with us and our website and services or when you apply for a job, including:
- Directly from you when you provide it to us, such as when you contact us by phone, email, or otherwise.
- Automatically through the use of cookies, server logs, and other similar technologies when you interact with our website, and emails.
- From other sources, including, for example, our affiliates, business partners, service providers, and other third parties, or from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.
| Context | Types of Data | Primary Purpose for Collection and Use of Data |
|---|---|---|
| Client Information | We collect the name, and contact information, of our clients and their employees with whom we may interact. | We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing. |
| Cookies and First-Party Tracking | We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. | We have a legitimate interest in making our website operate efficiently. |
| Cookies and Third-Party Tracking | We may place tracking technology on our website that collects analytics, records how you interact with our website, or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide advertising about products and services tailored to your interests. That third party might also collect information over time and across different websites in order to serve advertisements on our website or other websites. | Where required by law, we base the use of third-party cookies upon consent. |
| Demographic Information | We collect personal information, such as your age or location. | We have a legitimate interest in understanding our users and providing tailored services. |
| Employment | If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment. | We use information about current employees to perform our obligations to employees. In some contexts, we are also required by law to collect information about employees or applicants. We also have a legitimate interest in using your information to have efficient staffing and work force operations. |
| Feedback/Support | If you provide us feedback or contact us for support we will collect your name and email address, as well as any other content that you send to us, in order to reply. | We have a legitimate interest in receiving, and acting upon, your feedback or issues. |
| Mailing List | When you contact us for a service order placement we collect your email address or postal address. | We share information about our services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services. |
| Service Order Placement | We collect your name, billing address, email address, home address, age of the home, phone number, and credit card number when you place an order. | We use your information to perform our contract to provide you with products or services. |
| Public Health and Safety | In certain situations where a serious public health threat has been identified, we may collect information from employees, guests, and other individuals accessing our facilities. This may include medical and health information, such as body temperature, symptoms, and underlying health conditions. In some cases, we may also collect medical, health, and related information about an employee’s children, family member, or other individuals under the employee’s care. | We have a legitimate interest in protecting the health and safety of our employees and guests. In some jurisdictions we may be required by law, regulation, or governmental order to collect and retain information related to issues of public health and safety. We have a legitimate interest in complying with the laws in the jurisdictions in which we operate. |
| Surveys | When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. | We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization. |
| Website interactions | We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. | We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. |
| Web logs | We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. | We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular. |
How We Share Information.
In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:
- Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company. Unless you contact us at the contact information described below and request to opt-out of such sharing, you acknowledge that sharing of personal information with affiliates and via fundamental corporate transactions may occur.
- Other Disclosures Without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
- Service Providers. We may share your information with service providers performing business purposes on our behalf. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
- Other Disclosures with Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.
Your Choices
Depending on applicable law where you reside or are located, you may be able to assert certain privacy rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in determining whether to extend those rights.
Your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons.
- Access To Your Personal Information. You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
- Changes To Your Personal Information. We rely on you to update and correct your personal information. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
- Deletion Of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
- Promotional Emails. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
[[Opt-out of Targeted Advertising. You may opt-out of online tracking based targeted advertising (e.g., cookies) by Global Privacy Control (GPC) signals enabled by customers on their web browser or web browser extension as valid opt-out requests where required by applicable law. Please note that your opt-out preference signal will be applied only to your current browser and device. For more information about GPC, please visit Global Privacy Control.
Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.]]
Please note, not all of the rights described above are absolute, and they do not apply in all circumstances.
In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity.
Submitting Requests
You may exercise the rights described above by contacting us as indicated in the “Contact Information” section below. If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.”
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of a written authorization by that individual indicating that you are able to act on another person’s behalf.
Marketing Communications. You may choose to provide us with your email address to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications. If you sign up to receive text messages from us that contain promotional information, you can opt-out of receiving future messages by replying “STOP.”
How We Protect and Retain Information
No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
We retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.
Transmission Of Information To Other Countries
Our website and services are intended for U.S. audiences. If you reside elsewhere, please know that your information may be processed in the United States or a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage, and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
Third-Party Applications/Websites
For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.
Children
Our websites and online services are not intended for children under the age of 13 and we do not knowingly collect personal information from children under age 16, without parental consent. Children under the age of 13 should not provide their personal information to us.
Changes To This Privacy Policy
We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and/or “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified. If we make a material change to our privacy notice, we will attempt to notify you through email or through a website pop-up.
Additional Information For California Residents
If you are a California resident, the following privacy disclosures may apply to you in addition to the rest of the Privacy Policy.
- California Shine the Light. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the Contact Information section above.
- Notice of Collection. We may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” your personal information for money. As discussed elsewhere in the Privacy Policy, we use cookies and similar tracking technologies for purposes of targeted advertising. For details regarding how we use personal information, please see the Information We Collect section of the Privacy Policy. For information regarding how long we retain personal information, please refer to the How We Protect and Retain Information section of the Privacy Policy.
- California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined under California law): social security numbers/state identification cards/passport numbers, and payment information such as credit/debit card numbers. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.
Contact Information
If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
