Privacy Policy.

This Privacy Policy describes how CTC Technologies, Inc. collects, uses, and discloses information associated with an identified or identifiable individual (referred to in this Privacy Policy as “Personal Data”) and what choices you have around this activity. If you have any questions, please don’t hesitate to contact us.

Effective date: May 1, 2024

When we refer to “CTC”, we mean CTC Technologies, Inc.

Applicability of This Privacy Policy

This Privacy Policy applies to CTC’s website and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with CTC. If you do not agree with this Privacy Policy, then do not access or use the Services or Website or any other aspect of CTC’s business. For the avoidance of doubt, this is the only privacy policy that applies to CTC.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the CTC platform (“Third-Party Services”), or any other third-party products, services or businesses who will provide their services under their own terms of service and privacy policy. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of data such as messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls its instance of the Services and any associated Customer Data.

Information We Collect And Receive

CTC will collect and receive information through operating the Services and Website, and through other interactions with CTC. Such information will include Customer Data and other information and data (“Other Information”) in a variety of ways:

Customer Data. Customers or individuals granted access to a Workspace by a Customer (“Authorized Users”) routinely submit Customer Data (such as messages, files or other content submitted through Services accounts) to CTC when using the Services.
Other Information. CTC also collects, generates and/or receives the following categories of Other Information:some text
1. Workspace and account information: To create or update a Workspace account, you or our Customer (e.g. your employer) supply CTC with an email address, phone number, password, domain, and/or other account set up details. In addition, Customers that purchase Services provide CTC (or its payment processors) with billing details such as credit card information, banking information, and/or a billing address.
2. Usage information:some text
  - Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way that an Authorized User uses the Services.
  - Log data. As with most website and technology services delivered over the Internet, our servers automatically collect information when you access or use our Website or Services and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page you visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, and your language preferences.
  - Device information. CTC collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data.
  - Location information. We receive information from you, our Customers and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer (who is our Customer) or an IP address received from your browser or device to determine approximate location to assist with localization or for security purposes.
3. Cookie information: CTC uses a variety of cookies and similar technologies in our Website and Services to help us collect Other Information.
4. Third-Party Services information: A Customer can choose to permit or restrict Third-Party Services and CTC can receive personal data from such Third-Party Services. Typically, Third-Party Services are software that integrate with our Services, and a Customer can permit its Authorized Users to enable and disable these integrations. CTC may also develop and offer CTC applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with CTC. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to CTC. When a Third-Party Service is enabled, CTC is authorized to connect and access Other Information made available to CTC in accordance with our agreement with the provider of the Third-Party Service and any permission(s) granted by our Customer (including, by its Authorized User(s)). We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
5. Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to import (such as importing an address book to find coworkers, contacts or calendar from a device or API), forward or upload to the Services (for example, when sending emails to the Services) is collected when using the Services.
6. Third-Party data: CTC may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes. Or it might be more specific: for example, how well an online marketing or email campaign performed.
7. Additional information provided to CTC: We also receive Other Information when submitted to our Website or in other ways, such as responses or opinions you provide if you participate in a focus group, contest, activity or event, feedback you provide about our products or services, information you provide if you apply for a job with CTC, enroll in a certification program or other educational program hosted by CTC or a vendor, request support, interact with our social media accounts or otherwise communicate with CTC.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services.

How We Process Your Information and our Legal Bases for Doing So

Customer Data will be used by CTC in accordance with a Customer’s instructions, including to provide the Services, any applicable terms in the Customer Agreement, a Customer’s use of Services functionality, and as required by applicable law. CTC is a processor of Customer Data and the Customer is the controller. The Customer may configure settings, access, modify, export, share, and remove Customer Data, and otherwise apply its policies to the Services.

CTC uses Other Information to operate our Services, Website, and business. More specifically, CTC uses Other Information for the following purposes:

Compliance With A Legal Obligation:
CTC processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your profile picture or IP address.

We use Workspace and account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, Audio and video metadata, and Additional information provided to CTC for compliance with a legal obligation.

Legitimate Interests:
We rely on our legitimate interests or the legitimate interests of a third-party where they are not outweighed by your interests or fundamental rights and freedoms ("legitimate interests").

To provide, update, maintain and protect our Services, Website and business.
This includes the use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.some text
- It is in our and your interests to provide, update, maintain and protect our Services, Website, and business.
To develop and provide search, learning and productivity tools and additional features.
CTC tries to make the Services as useful as possible. For example, we may:some text
- improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User;
- make Services or Third-Party Service suggestions based on historical use and predictive models;
- identify organizational trends and insights;
- customize a Services experience; or
- create new productivity features and products.
some text
- It is in our interest and in the interest of Customers and Authorized Users to continuously improve and develop the customer support we provide.
To investigate and help prevent security issues and abuse.
We may use a variety of tools such as device fingerprinting to prevent issues and abuse. We may process, including in an automated fashion, Other Information to better understand how CTC is used or to prevent spam or abuse.some text
- It is in our interest to keep the Service secure and to detect, prevent, and address abuse (such as spam) and to investigate and take action in respect of suspicious activity on the Services.
To aggregate or de-identify information.
In some cases, we aggregate or de-identify information we have associated with you and use the resulting information, for example, to improve the Services.some text
- It is in our interest to research and improve the Services;
- It is in the interests of Customers and Authorized Users to practice data minimization and privacy by design in respect of their information.
Share information with others including law enforcement and to respond to legal requests.

some text
- It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of CTC, violations of our terms or other harmful or illegal activity; to protect ourselves, our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.

We use account information, Third-Party Services Information, Third-Party data, and Additional information provided to CTC for the following legitimate interests:

To communicate with you by responding to your requests, comments and questions.
If you contact us, we may use your Other Information to respond.some text
- It is in our, our Customers’ and Authorized Users’ interests to facilitate communication (for example to answer questions from Customers).
To send service emails and other communications.
For example, we may:some text
- send you service, technical and other administrative emails, messages, and other types of communications; or
- contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. It is in our Customers and Authorized Users’ interests to address service-related issues.

We use account information and Usage information for the following legitimate interests:

For billing, account management and other administrative matters.
CTC may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.some text
- It is in our interest to facilitate the effective provision and administration of the Website and Services.

We use account information, Usage Information, Cookie information, Third-Party Services Information, Third-Party data, and Additional information provided to CTC for the following legitimate interests:

To send marketing emails and other communications.
We sometimes send emails about new product features, promotional communications or other news about CTC. These are marketing messages so you can control whether you receive them. some text
- It is in our interest to promote the Website and Services and send our direct marketing.

How We Share and Disclose Information

This section describes how CTC may share and disclose Information, as described in the section entitled 'Information We Collect and Receive' above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. CTC does not control how a Customer or any third party chooses to share or disclose Information.

The Customer’s Instructions. CTC may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.some text
- To enable CTC to follow our Customers’ instructions, CTC provides several administrator controls.
- Customers may also provide their Authorized Users with the ability to adjust the audience and visibility of certain Customer Data.
Collaborating with Others. Information, such as an Authorized User’s profile and organizational information, may be shared. In many instances, CTC includes either administrator controls or user controls, depending on the use case, with respect to external collaboration. Authorized Users may also decide to expand the visibility of certain content and Customer Data, such as files.
Customer access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information.
Third-Party service providers and partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist CTC with verifying Owners and Customers, or we may share business information to develop strategic partnerships with Third-Party service providers to support our common customers. In this respect, depending on the Third-Party service provided, CTC may share your Information.
Third-Party Services. A Customer may enable, or permit Authorized Users to enable, Third-Party Services. We require each Third-Party Service provider to disclose all permissions for information accessible through the Services, but we do not guarantee that they do so. When Third-Party Services are enabled by a Customer or an Authorized User, CTC may share Information with Third-Party Services. Third-Party Services are not owned or controlled by CTC and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the provider for any questions.
Organizers and sponsors of Events/Webinars. If you attend an event or webinar organized by CTC, we may share your profile and organizational information with the event or webinar sponsors when you register, have your badge scanned, or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements.
Professional advisers. We may share your Information with professional advisers acting as service providers, processors, controllers, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Information containing personal data.
During a Change to CTC’s Business. If CTC engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of CTC’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of the Information described in the ‘Information We Collect and Receive’ section may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research.
Law Enforcement and Regulators. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. This may at times include information that CTC processes on behalf of CTC, including as pursuant to the terms of any data protection agreement between CTC and its Customers.
To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of CTC, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.
With Consent. CTC may share Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy. Data Retention

CTC will retain Customer Data in accordance with a Customer’s instructions (including to perform any applicable terms in the Customer Agreement and through Customer’s use of Services functionality) and as required by applicable law.

CTC may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for CTC to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

Security

CTC takes security of data very seriously. CTC works hard to protect Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process and store. Given the nature of communications and information processing technology, CTC cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on Third-Party sites.

Changes To This Privacy Policy

CTC may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, CTC will provide additional notice, such as via email or through the Services.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict CTC’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to lodge a complaint with the competent supervisory authority.

Contacting CTC

Please also feel free to contact CTC if you have any questions about this Privacy Policy or CTC’s practices, or if you are seeking to exercise any of your statutory rights. CTC will respond within a reasonable timeframe. You may contact us at sales@ctctechnologies.com or at our mailing address below:

For Customers and Authorized Users in the US and Canada:

CTC Technologies, Inc.
7136 Jackson Road
Ann Arbor MI 48103
United States

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