Effective on: July 1, 2020
This policy applies to the Website only. If you link to other third-party websites, platforms, and applications (“Third-Party Sites”), these Third-Party Sites may have their own privacy policies and terms and conditions which CWW encourages all parties to review before engaging any Third-Party Sites.
PERSONAL DATA COLLECTED BY CWW
“Personal data” (also known as “personal information”) means any information relating to an identified or identifiable natural person (the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
CWW will only process your personal data where it is fair and lawful to do so. Any such use shall be in accordance with this policy.
Some examples of personal data include name, address, screen name, profile picture, email address, telephone number, IP address, birthday, and lifestyle choices or preferences such as hobbies and interests.
CWW may receive personal data from different sources, which are discussed in detail below.
Information Provided Directly to CWW
CWW collects personal information voluntarily submitted by visitors to our Website. The types of information collected include:
Information Collected Automatically When Using the CWW Website
Information Collected From Other Sources
CWW may receive personal information from legitimate, commercially available sources, such as public databases, data aggregators, and various reputable third parties. The types of personal information that may be collected from such sources include:
Dependent on location, there may be solutions to assist in controlling online behavioral advertising preferences (such as whether certain third parties may collect and use site usage information for targeted advertising purposes). For example, in Europe, the website www.youronlinechoices.com permits the choice of which companies can deliver customized ads while Network Advertising Initiative’s Opt-Out Tool and the Digital Advertising Alliance’s Opt-Out Tool offer the same services in the U.S.
BASIS OF PROCESSING
Within the scope of this Policy, we may rely on one or more of the following legal grounds for processing your personal data:
In the context of this Policy, CWW acts as a data controller for the personal data we process.
HOW CWW USES PERSONAL INFORMATION
CWW may use and share personal information as set forth in this policy, as disclosed when you first submit your information, or as otherwise permitted under applicable law. CWW may use personal information to:
Mobile Message Service
CWW may make available a service through which text or other types of messages such as SMS (short message service), MMS (multimedia message service), or EMS (enhanced message service) can be received on a wireless or mobile device (“Mobile Message Service”). Upon subscription to a CWW Mobile Message Service, the user agrees to receive such messages from CWW at the address or mobile number provided for that purpose. It should be noted that wireless carrier standard rates apply to these messages. This does not apply if the user has elected to opt-out of receiving such messages.
Any person reading this policy represents that he or she is the owner or authorized user of the wireless device used to sign up for the Mobile Message Service and that he or she is authorized to approve the applicable charges. In addition to meeting certain age restrictions and any other terms and conditions associated with each Mobile Message Service, users may be required to register personal information such as your name, text message, wireless address, or mobile phone number. CWW may also obtain the date, time, and content of messages in the course of the use of the Mobile Message Service. CWW will use any information obtained in accordance with this policy. Please note that wireless carriers and other service providers may also collect data about wireless device usage and their practices are governed by their own policies.
By reading this policy, it is acknowledged and agreed that the Mobile Message Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. CWW does not guarantee that the use of the Mobile Message Service will be private or secure and CWW is not liable for any lack of privacy or security experienced. Users are fully responsible for taking precautions and providing security measures best suited to their situation and intended use of the Mobile Message Service. CWW may also access the content of wireless and/or mobile phone account with carriers for the purpose of identifying and resolving technical problems and/or service-related complaints.
WHOM DOES CWW SHARE YOUR PERSONAL INFORMATION WITH
As a global business entity, CWW may share personal information among other CWW offices, affiliates, and trusted third parties based in different countries around the world.
Such third parties include the following:
Our service providers may be located outside of the United States; however, we will either obtain your explicit consent to transfer your personal data to such third parties, or we will require that those third parties maintain at least the same level of confidentiality that we maintain for such personal data and ensure that appropriate safeguards are implemented to ensure the protection of your personal data.
Other Disclosure of Your Personal Information
We may disclose your personal data (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders, or (ii) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change, or (iii) to our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above.
We reserve the right to use, transfer, sell and share aggregated, anonymous data, which does not include any personal data, about our Website users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.
If we must disclose your personal data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your personal data will maintain the privacy or security of your personal data.
SAFEGUARDING PERSONAL INFORMATION
CWW takes all reasonable precautions to keep personal information secure.
CWW has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect personal data from unauthorized processing such as unauthorized access, disclosure, alteration, or destruction.
CWW requires any third parties that handle or process personal information on behalf of CWW to adhere to the same standards CWW holds itself to regarding safeguarding personal information. Access to information is only permitted among CWW employees and agents on a need-to-know basis.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
Personal Information will be retained by CWW in accordance with applicable laws, and the applicable retention periods in the CWW record retention policy. Personal information will be destroyed upon request unless applicable law requires destruction after the expiration of an applicable retention period. The manner of destruction shall be appropriate to preserve and ensure the confidentiality of the personal information given the level of sensitivity, value, and criticality to CWW.
This website is directed at adults and therefore is rarely used by any person considered a legal minor. CWW will obtain consent from a parent or guardian before the collection of any minor’s personal information. If CWW has collected personal information from a minor without the consent of a parent or guardian where such consent should have been obtained, CWW will delete that personal information as soon as possible. Any minor whose personal information is collected, used, or disclosed by CWW should review the terms of this policy should be reviewed with that minor’s parent or guardian.
EUROPEAN UNION (EU) REPRESENTATIVE
Harry Gerritsen has been appointed as CWW’s representative in the EU for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the EU (GDPR). Harry Gerritsen can be contacted in addition to CWW only on matters related to the processing of personal data. To make such an inquiry, please contact Harry Gerritsen at Harry.Gerritsen@craneww.com
The following information is intended for residents of California who belong to any of the following categories:
PERSONAL INFORMATION WE COLLECT
We may collect the following categories of personal information from and about you:
SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION
We collect personal information from a variety of sources, including:
HOW WE USE PERSONAL INFORMATION
We may use your personal information for the following purposes:
YOUR CALIFORNIA RIGHTS
California law grants residents of the state certain rights regarding the collection, use, and sharing of their personal information. Subject to certain limitations, California residents have the following rights:
If you are a California resident and would like to exercise any of the above rights, please submit your request at DataPrivacy@craneww.com or call us at +1 888-870-2726.
A request to disclose or delete your information must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, a resident of California and it must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
There may be circumstances where we will not be able to fulfill your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or for other permitted purposes. In such cases, we will inform you of the reasons we cannot fulfill your request.
If you are submitting a request through an authorized agent, we may require you to (1) provide the authorized agent written permission to do so and (2) verify your own identity and residency directly. We may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
If we make any material change to this policy, we will post the revised policy to this web page and update the “Effective on” date above to reflect the date on which the new policy became effective.
You are encouraged to review this policy whenever visiting this website to understand how your personal information will be used.
YOUR RIGHTS AND WHO TO CONTACT
If you are a data subject about whom we store personal data, you may have a right to:
• limit all future contact;
• be provided a copy of your personal information maintained by CWW;
• correct, update, or delete your personal information in CWW records; and
• opt-out of the use or collection of personal information
by sending an email to email@example.com.
In addition, you may have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states.
If you have any questions, comments, or concerns about this policy or any of the above, please contact:
Tracey L. Abram Anthony
VP and Chief Compliance Officer
1500 Rankin Road
Houston, TX 77073 USA
Please allow up to four weeks for us to reply.