Last updated January 15, 2018
This privacy statement describes how Cicero Transact, Inc. collects and uses the personal information you provide on our Web site: www.cicerotransact.com. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
Cicero Transact, Inc. (“Cicero”, “company”, “we”, “us”, or “our”) respects the privacy of our users (“user” or “you”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
COLLECTION OF YOUR INFORMATION
Please take care not to submit any sensitive or private information to other members or users of the site and do not submit any sensitive or private information in your public profile. Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Cicero’s profiles, or user messaging this information may be collected and used by others. Users which transmit confidential, personal, private, personally identifiable, or sensitive data to other users through their profile, or in any other way on Cicerotransact.com do so at their sole risk and Cicero will not be liable in any way.
We may collect information about you in a variety of ways. The information we may collect on the Site includes:
Personally identifiable information, such as your name, address, email address, and telephone number, passwords and security data, payment information, and social media login data that you voluntarily give to us when you register with the Site or when you choose to participate in various activities related to the Site (such as posting messages in our online forums or entering giveaways) or otherwise contacting us.. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using the Site.
Cicero allows for the creation of accounts and profiles which may be publicly searchable on the Internet and viewable by anyone. Information on your profile may be used to identify you personally by anyone. Users expressly agree that the information they upload to Cicero is not sensitive in nature and is true and accurate.
We collect passwords and similar security information used for authentication and account access.
Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Cicero website.
We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor, PayPal, and you should review its privacy policies and contact the payment processor directly to respond to your questions.
Social Media Login Data
We provide you with the option to register using social media account details, like your Facebook, Twitter, LinkedIn, or other social media account. If you choose to register in this way, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, social network username, location, birthdate, email address, friends list, profile picture as well as other information you choose to make public.
Data From Giveaways and Polls
Personal and other information you may provide when entering giveaways and/or responding to polls.
USE OF YOUR INFORMATION
Cicero collects and uses personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third party account *(such as your LinkedIn, Twitter, or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
To send you marketing and promotional communications for Business Purposes. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).
To send administrative information to you for Business Purposes, Legal Reasons and/or possibly for Contractual. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
Fulfill and manage your orders for Contractual reasons. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.
Deliver targeted advertising to you for our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
Administer prize draws for our Business Purposes. We may use your information to administer prize draws when you elect to participate in drawings.
Request Feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of our Sites.
To protect our Sites for Business Purposes. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
To enable user-to-user communications with your Consent. We may use your information in order to enable user-to-user communications with each user's consent.
To enforce our terms, conditions and policies for Business Purposes.
To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.
DISCLOSURE OF YOUR INFORMATION
We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
Your information may be disclosed as follows:
Compliance with Laws or to Protect Rights
We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests and Legal Rights
We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
We may share your information with our business partners to offer you certain products, services or promotions.
Our business partner, ESB Connect Limited, may pass your data to our carefully selected partner Opt-Me-In.com. Opt-me-in.com will provide you with offers, promotion and content from relevant brands. You can see who they work with here: http://www.opt-me-in.
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to the Site and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
When you post comments, contributions or other content to the Site, your posts may be viewed by all users and may be publicly distributed outside the Site in perpetuity.
With your Consent
We may disclose your personal information for any other purpose with your consent.
Interactions with Other Users
When you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Sites, such personal information (name, profile photo, personal information) may be viewed by all users and may be publicly distributed outside the Sites in perpetuity. If you interact with other users of our Sites and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Sites, and view your profile.
Sale or Bankruptcy
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.
Cookies and Other Tracking Technologies
We may use another company to place cookies on your computer to collect non-personally identifiable information to compile aggregated statistics for us about visitors to our site.
Our Web pages contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.
Our Web pages may also contain electronic images known as Web beacons (sometimes called single-pixel gifs) that are set by our third party partners. Web beacons are used along with cookies enabling our partners to compile aggregated statistics to analyze how our site is used.
We use a third party to gather information about how you and others use our Web site. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our site is used.
Links to Other Web Sites
Our Site includes links to other Web sites whose privacy practices may differ from those of Cicero Transact, Inc. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser's cookies files may also clear certain opt-out cookies, plug-ins, or settings.
By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. By using our implementation of the Google Maps APIs, you agree to allow us to gain access to information about you including personally identifiable information (such as usernames) and non-personally identifiable information (such as location). We will be collecting the following information: City, State, Country .
The Maps APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Union, please take a look at our EU User Consent Policy.
LENGTH OF TIME WE KEEP YOUR INFORMATION
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
SECURITY OF YOUR INFORMATION
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
POLICY FOR MINORS
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at the contact information provided below.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.
WHAT ARE YOUR RIGHTS?
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address.
Address: Cicero Transact, Inc.
1858 Pleasantville Road, Suite 110, Briarcliff Manor, NY 10510
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
OPTIONS REGARDING YOUR INFORMATION
You may at any time review or change the information in your account or terminate your account by:
Logging into user account settings and updating the user account.
Contacting us using the contact information provided.
Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
Logging into your account settings and updating your preferences.
Contacting us using the contact information provided.
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
YOUR PRIVACY RIGHTS
In some regions, such as the European Economic Area, you have rights under applicable data protection laws that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
ACCOUNT CLOSURE AND DATA DELETION
If you would at any time like to review or change the information in your account or terminate your account, you can:
■ Log into your account settings and update your user account.
■ Contact us using the contact information provided.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of ourSites. To opt-out of interest-based advertising by advertisers on our Sites visit http://www.aboutads.info/choices/ .
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
■ Note your preferences when you register an account with the site.
■ Access your account settings and update preferences.
Do not publish or upload information on the site that you consider private.
Be especially cautious when communicating with members.
Get third party expert advice on any deal related matter.
TERMS AND CONDITIONS
Please also visit our terms and conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website at https://www.cicerotransact.com/terms.
Cicero Transact, Inc.
1858 Pleasantville Road
Briarcliff Manor, NY 10510
Web page: https://www.cicerotransact.com/cpages/contact
CHANGES TO THIS STATEMENT
Cicero will occasionally update this Statement of Privacy to reflect company and customer feedback. Cicero encourages you to periodically review this Statement to be informed of how Cicero is protecting your information.