Last Updated: May 31, 2018
Cumberland Emerging Technologies, Inc. (“CET”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive when you visit and use our websites located at www.cet-fund.com and related websites (the “Site”). This Privacy Policy applies only to information that you provide to us through the Site. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this Privacy Policy regularly for any changes.
I. Information Collection
Personally Identifiable Information
At various locations on our Site, we may request that you supply us with Personally Identifiable Information, such as your name, email address, place of business, home or work addresses, and home or work telephone number. You will always know when we are collecting Personally Identifiable Information because we only collect Personally Identifiable Information when you voluntarily submit it to us.
If you choose to give us Personally Identifiable Information through our Site, we will collect and retain that information, and you consent to the transfer and storage of that information on our servers located in the United States. If you choose not to give us Personally Identifiable Information, we may not be able to provide you with any services you may request or require.
Non-Personally Identifiable Information
When you use the Site, our servers automatically record information that your browser sends whenever you visit a website or online service (“Log Data”). No Personally Identifiable Information is collected in this process. This Log Data may include, but is not limited to, your computer’s Internet Protocol address, browser type, the web page you were visiting before you came to the Site and information you search for on the Site. Like many websites, we may use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We may use “persistent cookies” to save your username and login password for future logins to the Site. We also may use “session ID cookies” to enable certain features of the Site, to better understand how you interact with the Site and to monitor web traffic routing on the Site and aggregate usage of the Site. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Site.
II. How We Use Information
Personally Identifiable Information
If you choose to contact us, we may use the Personally Identifiable Information you provide us, including your name, email address, and the content of your communication in order to consider and, as appropriate, reply to your communication, respond to your request, or contact you later.
If you provide us with any Personally Identifiable Information as part of an inquiry or application for an employment opportunity or a request for contact by a sales representative, we may use your Personally Identifiable Information to consider your application, inquiry, or request and, as appropriate, process your application, reply to your communication, or contact you later.
If you choose to download files from our Site, subscribe to our RSS feed, or join our email list, we may use the Personally Identifiable Information you provide us, including your name, email address, and employer name, in order to provide the requested service.
Non-Personally Identifiable Information
We use information we obtain by technical means (such as the automatic recording performed by our servers or through the use of cookies) for the above purposes and in order to monitor and analyze use of the Site and for the technical administration of the Site, to increase the functionality and user-friendliness of the Site, to better tailor both to your needs, to generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, and to verify that visitors and users to and of the Site meet the criteria required to process their requests.
III. Information Sharing and Disclosure
Except as otherwise provided in this Privacy Policy, we do not give, share, sell, or transfer any Personally Identifiable Information to any third party.
Approved Users
We may share your Personally Identifiable Information with our affiliates, agents, business partners, or third-party service providers (“Approved Users”) who help make our Site and its content available to you, who help us respond to your requests and inquiries, who help us administer some of our correspondence with you, and who otherwise help us better serve you,
We may share your Personally Identifiable Information with Approved Users so that they and we can offer you products and services that may be of interest to you.
We may also share Non-Personal Information and Log Data (“Aggregate Information”) and Personally Identifiable Information with third party service providers to facilitate the Site, to provide the Site on our behalf, to perform services related to administration of the Site (including, without limitation, maintenance, hosting and data center management services, web analytics and administration). These third parties have access to your Personally Identifiable Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Non-Affiliated Third Parties
We may share Aggregate Information with third parties for industry analysis, demographic profiling, and to deliver targeted advertising about other products and services. We do not share Personally Identifiable Information with third parties for marketing purposes.
Compliance with Laws and Law Enforcement
CET cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of CET or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
Business Transfers
CET may sell, transfer or otherwise share some or all of its assets, including Aggregate Information and your Personally Identifiable Information or de-identified information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
IV. Access and Corrections to Personally Identifiable Information
You may contact us at any time at privacy@cumberlandpharma.com to request any of the following: (1) learn what Personally Identifiable Information is held about you, if any, (2) withdraw your consent for us to use or share your Personally Identifiable Information if we are doing so (although such withdrawal will not affect the lawfulness of any such use or sharing of that information prior to your withdrawal of consent), (3) change or correct any Personally Identifiable Information we have about you, (4) instruct us to delete any Personally Identifiable Information we have about you, (5) request us to restrict the processing of your Personally Identifiable Information and not delete it, and (6) express any other concern you have about our use of your Personally Identifiable Information.
After receiving a request to change or correct your Personally Identifiable Information, we will make reasonable efforts to ensure that all of your Personally Identifiable Information stored in databases we actively use will be updated as soon as reasonably practicable. However, we reserve the right to retain in our archival files any information we remove from or change in our active website databases. In addition, it is not technologically possible to remove each and every record of the information you have provided to us. A copy of your Personally Identifiable Information may exist in a non-erasable form that will be difficult or impossible for us to locate.
V. Links to Other Sites
The Site may contain links to other websites. If you choose to visit a third party by clicking on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement of such third party’s privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites and services are not subject to the terms of this Privacy Policy and follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
VI. Our Policy Toward Children
CET does not knowingly collect Personally Identifiable Information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personally Identifiable Information without their consent, he or she should contact us at privacy@cumberlandpharma.com. If we become aware that a child under 13 has provided us with Personally Identifiable Information, we will endeavor to delete such information from our files as soon as possible.
VII. Security
CET is concerned with safeguarding your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. However, there is always some risk in transmitting information electronically. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet.
VIII. Cross Border Transfers
This Site is controlled and operated from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than the U.S. The information you provide to us may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide Personally Identifiable Information to CET, please be advised that we transfer Personally Identifiable Information to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
IX. Phishing
Identity theft and the practice currently known as “phishing” are of great concern to CET. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request any Personally Identifiable Information in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
X. California Residents
Residents of the State of California have the right to request a list of all third parties to which we have disclosed certain information during the preceding year for the third parties’ direct marketing purposes.
However, it is our policy to neither disclose Personally Identifiable Information, nor to sell such information to third parties for direct marketing purposes. In the future if this Privacy Policy changes in this respect, and you are a California resident and want such a list, please contact us at privacy@cumberlandpharma.com.
XI. Retention Period
Your Personally Identifiable Information will only be kept for as long as we reasonably consider necessary for achieving the purposes set out above or for as long as we are legally required to keep it. Please contact us for further details of applicable retention periods.
XII. Tracking
CET does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.
Third parties that have content embedded on CET’s websites such as a stock ticker may set cookies on a user’s browser and/or obtain information about the fact that you visited a specific CET website from a certain IP address. Third parties cannot collect any other Personally Identifiable Information from CET’s websites unless you provide it to them directly.
Google Analytics is an element of the Site. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the IP address, and the type of operating system used in the devices used to access the Site. By downloading and using a browser plugin provided by Google (available here: https://tools.google.com/dlpage/gaoptout), you can choose to opt out of Google Analytics.
XIII. Contacting Us
If you have any questions about this Privacy Policy, please contact us at privacy@cumberlandpharma.com.