1. Introduction and Overview

    This Privacy Policy provides a comprehensive description of how Cramer-Krasselt (“Cramer-Krasselt,” “C-K,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices regarding such information. It applies to the web site located at www.c-k.com and any online location that links to this Privacy Policy (the “Service”).

    By using or accessing the Service, you signify your agreement to be bound by this Privacy Policy. If you do not agree, you may not access or otherwise use the Service.

    This Privacy Policy does not apply to information collection activities outside of the Service, such as CK’s products and services that CK’s clients may use to collect information on their own behalf (unless otherwise stated below or at the time of collection). For information about processing on behalf of our clients, please see the section entitled “Information on Behalf of Our Clients” below.

    If you are a California resident, please see the “Additional Disclosures for California Residents” section. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.

  2. Information Collection

    1. Information You Provide

      We collect information about you when you use the Service or interact with us offline, including information you provide when you access our content, or apply for a job. The following categories of information we collect and have collected in the last 12 months:

        • Contact Data, including your first and last name, email address, postal address, and telephone number.
        • Content, including content within any messages you send to us (such as feedback and questions).
        • Job Applicant Data, including your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.

      You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

    2. Information Collected Automatically

      In addition, we automatically collect information when you use the Service. The categories of information we automatically collect and have collected in the last 12 months includes:

      • Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, the time of day you browse, and your referring and exiting pages.
      • Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.
      • Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).

      We use various current – and later – developed tracking technologies to automatically collect information when you use the Service, including the following:

      • Log Files, which are files that record events that occur in connection with your use of the Service.
      • Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
      • Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our conversions and bring you advertising both on and off the Service.

      For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

    3. Information on Behalf of Our Clients

      We provide advertising and marketing products and services for our clients and collect and process information about individuals (including through tracking technologies) at the direction of our business clients (“Client Data”). Client Data has historically included contact data, demographics, service use data, device connectivity and configuration data, and location data, among other information. Our processing of Client Data is governed by the terms of our service agreements with our clients, and not this Privacy Policy. To the extent we combine Client Data with information we have collected through the Service, we will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by our clients. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their own privacy policies.

      For further information on your rights and choices regarding Client Data, see the “Your Rights and Choices” section below.

    4. Information from Other Sources

      We also collect information from other sources. The following are the categories of sources we collect information from:

      • Data brokers or resellers from which we purchase data to supplement the data we collect.
      • Publicly available sources, including data in the public domain.
      • Social media sources

  3. Use of Information

    We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include:

    • Operate and manage our Service, including provide access to our content.
    • Perform services requested by you, such as respond to your comments, questions, and requests.
    • Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
    • Preventing and addressing fraud, breach of policies or terms, and threats or harm.
    • Monitoring and analysing trends, usage, and activities.
    • Conducting research, including focus groups and surveys.
    • Improving the Service or other Cramer-Krasselt websites, apps, marketing efforts, products, and services.
    • Developing and sending you advertising and direct marketing, including advertisements and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
    • Fulfilling any other business or commercial purposes at your direction or with your notice and/or consent.

    Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

  4. Sharing of Information

    We share information we collect in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose, may disclose, and have shared information with in the last 12 months, include the following:

    • Service Providers We share information with entities that process information on our behalf for our business purposes. Service providers assist us with services such as data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
    • Vendors and Other Parties We share information with vendors and other parties for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
    • Clients We share information with our clients in connection with us processing information on their behalf. For example, we share information with our clients to respond to your questions and comments, comply with your requests, market, and advertise to you, and otherwise comply with applicable law.
    • Partners We share information with our partners in connection with offering co-branded services or engaging in joint marketing activities.
    • Merger or Acquisition We may share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business
    • Security and Compelled Disclosure We may share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
    • Facilitating Requests We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Service.
    • Consent We share information with notice to you and your consent.

    Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

  5. Social Media and Technology Integrations

    We offer parts of our Service through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Service. Some examples include:

    • Links Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
    • Brand Pages We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Cramer-Krasselt in a tweet or post), we may use your reference on or in connection with our Service.

    Please note that when you interact with other entities, including when you leave our Service, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

  6. Analytics and Advertising

    We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

    As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

    As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

    For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, and Interest-based Advertising, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

  7. Your Rights and Choices

    1. Tracking Technology Choices
      1. Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
      2. Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do regarding these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or act with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

      Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

    2. Analytics and Interest-Based Advertising.Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; and (ii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
    3. E-mail CommunicationsYou can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or Cramer-Krasselt’s ongoing business relations.Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.

  8. Children

    The Service is intended for a general audience and is not directed at children under (13) years of age. We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at privacy@c-k.com. We will remove the data to the extent required by applicable laws. We do not knowingly “sell” the personal information of minors under 16 years old who are California residents.

  9. Data Security

    We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

  10. International Transfer

    We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.

  11. Changes to this Privacy Policy

    We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.

  12. Contact Us

    If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

    By email:

    privacy@c-k.com

    By mail:

    225 N. Michigan Ave
    Chicago, Illinois 60601
    Attn: Director of Agency Communications

    If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at 225 N. Michigan Ave, Chicago, Illinois 60601 Attn: Director of Agency Communications.

  13. Additional Disclosures for California Residents

    • Roles.

      Our Service is intended to provide information to our business clients and job applicants. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) Cramer-Krasselt conducting due diligence regarding, or providing or receiving a product or service to or from your employer.

      If you are a California resident and we as a service provider have processed personal information about you on behalf of our clients and you wish to exercise your CCPA rights, such as an access or deletion request, please inquire with our business client directly. If you wish to make your request directly to us, please contact us as set out in Section 12 above and provide the name of our client on whose behalf we processed your personal information. We will refer your request to that client and will support them to the extent required by California privacy law in responding to your request. If you are a California resident and we as a service provider have processed personal information about you on behalf of our clients and you wish to exercise your CCPA rights, such as an access or deletion request, please inquire with our business client directly.

    • Shine the Light

      Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.