Privacy Policy

Last Updated: 11/2/2021

Thank you for your interest in the Calico Group (hereinafter, the “Company,” “we,” or “us”). This Privacy Policy (“Privacy Policy”) sets forth the terms and conditions with respect to how the Company processes personal information on you when you access or use any of the websites that we own, license, or operate (collectively, our “Websites”). This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING OUR WEBSITE, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY.

1. Scope / Data Controller

This Privacy Policy describes how the Company processes personal information in our role as a “data controller” (i.e., when the Company determines the purposes for which, and the means by which, personal information is processed). This Privacy Policy applies to personal information that the Company processes from our Websites. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and is not otherwise subject to a data protection law, statute, or regulation. The Company may anonymize or de-identify personal information, and such anonymized or de-identified data is not subject to this Privacy Policy, and the Company may use such data for any purpose.

2. The Types and Categories of Personal Information We Collect

The Company collects personal information in order to provide our Websites and services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to the Company, we may not be able to provide you the services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:

Personal Information

Category

Description/Examples

Personal Identifiers

Identifiers, such as your name, email address, telephone number, and any other personal identifiers you voluntarily provide to us.

Online Identifiers (For more information, see “Cookies and Technical Data” below)

Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.

Commercial Information

Records of the services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our services.

Business Contact Data

Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.

Marketing and Communications Data

Information with respect to your marketing preferences and your subscriptions to our publications and alerts.

Internet and Electronic Network Data

Data pertaining to your access or use of our Websites, including browsing history, search history, and information regarding your interaction with our Websites or advertisements embedded on our Websites or other third-party websites.

Your Feedback

Information you provide about our services, which may include data gathered from any of our surveys or reviews submitted by you.

Geolocation Data

Information about the general city, state, or region in which a user of our Websites is located.

Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)

If you apply for a job with the Company, we collect information set forth in your resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.

3. Cookies and Technical Data

When you access our Websites, we collect certain data automatically using technical means and tools. This data relates to your device and your experience on our Websites and other third-party websites, including the following:

Usage and Device Data. When you access and use our Websites, we automatically collect details of your access to and use of our Websites, including traffic data, usage logs and other communication data, and the resources that you access and use on or through our Websites (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. Our Websites may collect “diagnostic” data related to your user experience, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within our Websites. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of our Websites may become inaccessible or not function properly. We use cookies to identify you and your interests, to remember your preferences, to facilitate our marketing, to track your use of our Websites, to control access to certain content on our Websites, to protect the integrity and security of our Websites, to assist us in processing requests that you make, to administer our Websites, for research purposes, and to track and analyze statistical usage and volume information from our Websites, In addition, our Websites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of our Websites. We use the following third-party cookies and other tracking technologies on our Websites:

• Google Analytics. We use “Google Analytics” to collect information about use of our Websites. Google Analytics collects information such as how often you visit our Websites, what specific webpages you access, and what other sites you used prior to coming to our Websites. We use the information we get from Google Analytics only to improve our Websites. Google Analytics collects only the IP address assigned to your device on the date you visit our Websites, rather than your name or other personal information. We do not combine the information collected through the use of Google Analytics with other personal information. You can prevent Google Analytics from recognizing you on return visits to our Websites by disabling cookies on your browser. Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) which are used along with cookies to compile aggregated statistics to analyze how our Websites are used. You can find additional information on how to install a browser add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

4. Sources of Information

We collect the personal information identified herein directly from you when you use our Websites, or from third-party sources when you apply for employment with us:

First Party / Direct Collection. We collect personal information directly from you when you use our Websites, such as when you submit a question or comment.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use our Websites (see “Cookies and Technical Data” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, background check providers, social networking providers, advertising companies, our service providers, and third-party references.

5. How We Use Your Information / Purpose of Collection

We may use the personal information we collect about you in order to perform our services, comply with our legal obligations, and promote our business interests, including to (i) provide, operate, maintain, improve, and promote our Websites, (ii) enable you to access and use our Websites, (iii) process and complete transactions, and send you related information, including purchase confirmations and invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for our Websites, (v) furnish technical notices, updates, security alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our services, features, surveys, newsletters, offers, promotions, contests, and events), (vii) process and deliver contest or sweepstakes entries and rewards, (viii) monitor and analyze trends, usage, and activities in connection with our Websites to promote our business interests (e.g., marketing), (ix) investigate and prevent fraudulent transactions, unauthorized access to or use of our Websites, and other illegal activities, and (x) personalize our Websites, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, the Company may collect and use your personal information for any other purpose for which we obtain your consent. For the avoidance of doubt, you hereby agree that the Company may contact you via any means, including SMS/text message and email, to furnish you information regarding our products, goods, use of Websites, and similar data and information pertaining to a commercial transaction.

6. Sharing Information / Third-Party Disclosures

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.

Intra-Group Sharing. We may share your personal information with our parent company, and to and among our affiliates and subsidiaries, provided they will use such personal information only for the purposes already described in this Privacy Policy.

Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing our Websites, conducting surveys and marketing on our behalf, processing transactions, and performing analyses to improve the quality of our services.

Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.

Business Restructuring. Circumstances may arise where for strategic or other business reasons the Company decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of the Company’s assets.

Disclosure for Other Reasons. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, the Company may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.

In the event that you facilitate a transaction with the Company, or request information from or otherwise engage with us, and such activities require the Company to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct the Company to intentionally disclose your personal information to the service provider or third party.

7. Social Media

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on one of these platforms for customer support or otherwise, we may contact you via the social media’s direct message tools. Those communications are governed by this Privacy Policy as well as the policies and terms of the relevant social media platform. The information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. Our Websites include social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on our Websites. These features may collect your IP address and which webpage you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Websites. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

8. Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, our Websites may include links to third-party websites or provide you the opportunity to disclose information directly to third parties. Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

9. Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with our services, to facilitate transactions you have requested, or to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

The Company is based in the United States, and the personal information that we collect and process is retained and stored in the United States. The Company uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby consent to your personal information being transferred to, and stored in, the United States and in other third countries.

10. Security

We seek to safeguard your personal information and implement and maintain security measures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO OUR WEBSITES AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

11. No Data Collected from Children

Our Websites are not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under eighteen (18) years of age. If you are under the age of eighteen (18), you are prohibited from accessing or using the services (including our Websites) or from providing us with your personal information, unless you provide us written and verifiable authorization from your parent or legal guardian permitting you to do so.

12. Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to the Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY, YOU EXPRESSLY REPRESENT AND WARRANT TO THE COMPANY THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE THE COMPANY WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT THE COMPANY’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY THE COMPANY FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY.

13. Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. You must directly notify the Company of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.

14. Email Marketing and Your Rights

You have the right to opt out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.

15. California Privacy Rights / Direct Marketing

As permitted by California Civil Code Section 1798.83, California residents who have supplied us with personal information (as defined in the statute) may, under certain circumstances, request and obtain certain information regarding any disclosure by us of personal information to third parties for their direct marketing purposes. The Company does not knowingly disclose your personal information to third parties who use such personal information to engage in direct marketing.

16. California Privacy Rights / Consumer Privacy

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents have additional data privacy rights, including the following:

• The Right to Know: The right to know about what personal information is collected about you, and our intended use and purpose for collecting your personal information. The personal information that we collect from you, the purposes for which it is used, the source of such personal information, and the parties to whom we share your personal information, among other issues, are set forth in this Privacy Policy (see above).
• The Right to Access: The right to access general categories and/or the specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the personal information we have collected, used, disclosed, or sold about you, the sources from which the personal information was collected, the business or commercial purpose for which your personal information was collected, used, disclosed, or sold, and the third parties with whom we have shared your personal information.
• The Right to Deletion/Erasure: The right to request that we delete/erase your personal information under certain circumstances.
• The Right of Data Portability: The right to request the Company to transfer, to the extent feasible, personal information in certain forms and formats.
• The Right to Nondiscrimination: The right not to be subject to discrimination for asserting your rights under the CCPA.

To exercise any of the CCPA’s data privacy rights set forth herein, please contact us in accordance with the “Contact Us” section listed below. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf. An authorized agent must be registered with the California Secretary of State to conduct business in California.

Privacy Request Verification Process. If you (or your authorized agent) makes any request related to your personal information under the CCPA, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. The Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two or three pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute and are subject to legal and regulatory exceptions and exemptions. For more information on the CCPA, please see: https://oag.ca.gov/privacy/ccpa.

Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the sale of their personal information. The Company does not sell your personal information to third parties for profit or other valuable consideration. In addition, our Websites are not directed at, and should not be used by, minors under the age of eighteen (18), and therefore the Company does not knowingly collect (or sell) the personal information of minors under eighteen (18) years of age.

17. Nevada Privacy Rights

The Company does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.

18. Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

19. Persons with Disabilities

The Company strives to ensure that every person has access to information related to our services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.

20. Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We may share your personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.

21. Events and Video Teleconferencing

The Company hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.

22. Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of our services, and continued use of our services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto, which shall supersede and control over any previous privacy terms and conditions. We may, in our sole discretion, provide you direct communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

23. Contact Us

If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact us at the following: (email) [email protected]; (mail) The Calico Group, ATTN: Privacy Request, the Terrace, 2801 Via Fortuna, Suite 675, Austin, TX 78746; or, (telephone)1-888-398-4361.