Privacy Notice

Privacy Notice

This is the web site of Connex International, Inc.

Our postal address is:

46 Federal Road, Suite F
Danbury, CT 06810

We can be reached via e-mail at policy@connexintl.com or you can reach us by telephone at (800) 426-6639.

Connex International General Privacy Notice

LAST UPDATED: June 4, 2021
EFFECTIVE DATE: June 4, 2021

Recent Changes to Our Privacy Notice in this Update

The privacy and security of Personal Information is important to us. We have made changes to this Privacy Notice that apply to Personal Information we collect, use, share and store on or after the date in the “Last Updated” section above. These changes include:

(1) Detailed information regarding what Personal Information we collect, how we collect it, and how it is used;

(2) Further descriptions of the parties with whom and for what purposes Personal Information is shared; and

(3) What rights are available to residents of California and to individuals in the EU/EEA, Switzerland and UK including regarding international data transfers.

To learn more, please review the full Privacy Notice below.

Introduction

At CONNEX INTERNATIONAL (“Connex” “Connex Intl)), we value your privacy, and Connex has created this Privacy Notice to describe how Connex collects, uses, shares and stores Personal Information that is collected by Connex (“we,” “us,” or “our”) through this Site and the Services we provide and the choices you have. The term “Personal Information” means information that can be used to identify you personally, alone or in combination with other information available to us.

This Notice excludes websites and online services that have separate privacy notices and do not link to this Notice or incorporate it by reference. “You” or “your” refers to those who access and/or use Connex’s Site and/or Services.

PLEASE READ THIS NOTICE AND THE CONNEX TERMS AND CONDITIONS IN FULL SO YOU UNDERSTAND OUR PRIVACY PRACTICES BEFORE YOU USE OUR SERVICES. BY USING OUR SERVICES AND BY PROVIDING PERSONAL INFORMATION AND OTHER INFORMATION THROUGH OUR SERVICES, YOU ACKNOWLEDGE THAT PERSONAL INFORMATION WILL BE PROCESSED PURSUANT TO THE TERMS OF THIS NOTICE. IF YOU DO NOT AGREE TO ANY TERM IN THIS NOTICE, PLEASE DO NOT USE THE CONNEX SERVICES OR PROVIDE ANY PERSONAL INFORMATION.

MINORS

This Site is not intended for persons under 18 years of age. Connex does not knowingly solicit or collect Personal Information from or about children under the age of 18 except as permitted under applicable law. If you become aware that Connex has inadvertently collected Personal Information about children under the age of 18 please contact us immediately at policy@connexintl.com.

CONTENTS

  1. What Personal Information we collect and why
  2. If you fail to provide Personal Information
  3. How we use Personal Information
  4. How we use Cookies and other tracking mechanisms
  5. How we share Personal Information
  6. Third Party links
  7. How we protect Personal Information
  8. How long we keep Personal Information
  9. Choices you have about how we use and disclose Personal Information
  10. How to manage or delete Personal Information about you
  11. For California residents
  12. For individuals in the European Union (“EU”)/European Economic Area (“EEA”)/Switzerland/UK
  13. International transfer of Personal Information
  14. Changes to our privacy notice
  15. Contact us

1. WHAT PERSONAL INFORMATION WE COLLECT AND WHY

We collect Personal Information directly from you as a user of our Site and Services, such as when you visit our Site, use our Services, sign up to receive special offers from us or register for a moderator or participant account with us. We also collect certain information automatically through your use of our Site or Services. Often, you choose what information to provide, but sometimes we require certain information for you to use and for us to provide you the Services.

1.1. Personal Information you provide.

“Personal Information” is any information relating to an identified or identifiable individual, or as defined under applicable law.

Because of the nature of our products and Services, we must collect Personal Information such as first and last name and email address, from call moderators, participants and other users of our Services. The kinds of Personal Information that we collect depends on the types of Services you use including when you join a meeting or event or access stored documents or recordings.  Our clients can also ask us to collect and provide them Personal Information about you.

We collect Personal Information directly from you, such as:

Registration and account set up data: When you sign up to use our Services, you provide us with your name (first and last), company name, mailing address, title or position phone number, email address, and a password/passcode to access your account. We use this information to create your account. We also use this information to help verify your identity, account and account activities to ensure the safety and security of your transactions.

Payment details when you complete a purchase: When you complete or authorize a purchase or similar transaction, we will ask for your email address, payment information, which may include a credit or debit card number, credit verification code (“CVV”), name (first and last), an expiration date for your credit or debit card, and billing information. We may also ask you to provide your phone number.

We use third-party payment processing companies to process your payment information. This information is used to fulfill your order. Connex does NOT store your full credit card number or CVV.

Contact information: When you contact us, we may collect your name (first and last), email address, or telephone number, client or account number, and any other Personal Information you voluntarily provide. We use your contact information to send you newsletters, share news about new solutions, features, and Services, respond to your requests and inquiries, or reach out to you about issues and questions about your account.

Your photos or images: If requested by you, we may, on your behalf, upload images or photos that you have provided us for use with our services, such as presentation slides, speaker bios and photos.

Information you provide to us when completing our surveys: If you choose to complete any of our surveys, you may share your name, email address, age, gender, answers to our surveys or comments and other information you choose to provide us in the comment fields. Our surveys are designed to collect your feedback in order for us to continually improve our Services. Participation in our surveys is completely voluntary. You choose whether to participate, and what to disclose. If you participate in a survey, your responses may be shared with third-parties we hire to conduct our surveys. We also may contact you for additional information needed to solve any issue you identify in your survey responses. We may also contact you in response to your request for help or to enter you in a drawing for a gift card to thank you for your participation in our survey.

Employment information (job applicants): When you apply for a position with us, we also collect Personal Information about you including your name, address, resume/CV, educational details, prior experience and qualifications and any other information you choose to provide. Connex Intl is an equal opportunity employer.

1.2. Personal information we collect from others.

At times it is necessary for us to supplement the Personal Information we receive from you with information from third party sources. For example, Connex verifies the billing address for all credit card transactions and may obtain credit reports for corporate customers. We use and store the Personal Information we obtain from these third- party sources in a manner consistent with this Privacy Notice.

We may also receive information about you in connection with certain features of our Site and Services. For example, we collect Personal Information (names and email addresses) when someone refers you to our Site or invites you to participate in our Services.

We may receive information about you and your interaction with our Services from our third-party business partners, and we may combine it with information we already have about you. We use this combined information to update, expand, and analyze our records about you; identify potential new customers; and create advertising tailored to your interests.

1.3. Other information we automatically collect.

Like many other websites, as you navigate through and interact with our Site and Services, we may use automatic collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Device information: We collect information relating to the device(s) you use to access the Services: the device model, operating system, browser type, unique device identifier, and IP address. This information is collected automatically when you use our Services. We use this information to make navigation of our Services easier, and to personalize the content you see. We will also use this information to conduct audits and to troubleshoot problems. These activities are done using cookies and other tracking technologies. Please see Section 4 (“HOW DO WE USE COOKIES AND OTHER TRACKING MECHANISMS”) and our Detailed Cookie Use Notice for more information on cookies and other tracking technologies.

You can also learn more about cookies and how to manage them by visiting allaboutcookies.org.

Browsing history: We also collect the following information about your use of our Services: the types of content that you view or interact with, and the frequency and duration of your activities on the Services. While permission for us to collect this information is not mandatory, our access to this information is essential to helping us improve the Services’ functionality, generate web analytics, improve our product and Services offerings, and troubleshoot problems.

2. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

Where we need to collect Personal Information by law, or under the terms of a contract we have with you or another client, and you do not provide the Personal Information requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a Service you have with us. We will notify you if this is the case at the time.

3. HOW WE USE PERSONAL INFORMATION

Connex uses Personal Information in a number of ways described below.

Performance of a contract: We process Personal Information in order to fulfill a contractual agreement with you to provide you our Services and operate the features. This may include:

  • establishing an online account at your request;
  • processing purchase orders including billing and collecting payment for our Services;
  • tracking and keeping you informed about the status of your order (including to send you transactional emails notifying you about your orders, account information, changes to the Services, updates to our online documents, and other matters as required by law. You may not opt-out of transactional emails);
  • providing customer service (e.g., answering your questions or responding to a request through phone, email or online chat). Please note that phone conversations and online chat sessions may be monitored or recorded in accordance with applicable law.

Legitimate business reasons: We process Personal Information described above when we have legitimate business reasons to do so, or pursued by us or a third party. This may include:

  • operating, maintaining, and improving our Site, and Services;
  • performing analytics to diagnose problems or analyze use of our Site and Services;
  • allowing you to interact with certain third-party content service providers;
  • administering online surveys or special offers from us or through our third-party business partners;
  • internal record keeping;
  • enhancing other information we have about you to help us better understand you and determine your interests;
  • enforcement of our corporate reporting obligations and Terms and Conditions; and
  • aggregating and/or anonymizing Personal Information. We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

Legal obligation compliance: We process Personal Information described in this Notice where it is necessary to comply with legal obligations to which we may be bound. This includes:

  • for fraud prevention, public safety; and
  • to comply with law (e.g., tax and accounting), regulation, court order, subpoena, or other legal process.

With your consent: We process Personal Information (including your name, email address, or physical address/telephone number) when we have your consent to do so. This includes:

  • to communicate with you by email, or postal mail in order to send you promotional offers, newsletters, information on us, our Services, and other marketing communications and third-party promotions administered by Connex in accordance with your preferences;
  • to conduct customer research; and
  • to identify your preferences so we can notify you of new or additional products, services, and promotions that may be of interest to you.

Tell a Friend Referral Services:  If you chose to tell a friend about our Site, we ask you for your friend’s name and email address. We may send your friend an email(s) inviting your friend to visit our Site. To request removal of this information from our database, your friend may contact Connex by sending a message to policy@connexintl.com.

Job Applications: We also process Personal Information in order to consider an application for employment, including review of your supplied resume. The information may be saved in our files for future review and consideration. The information will be shared internally on a need-to-know basis, and will not be given to any third parties other than our service providers who process data on our behalf.

We will only use Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like more information about how the processing for the new purpose is compatible with the original purpose, please contact us at the details in Section 15 below.

4. HOW WE USE COOKIES AND OTHER TRACKING MECHANISMS

Cookies: Like most companies, we may collect some Personal Information about you through a “cookie.” “Cookies” are small bits of data cached or stored on your computer based on your internet activity. They can be placed on your computer both by us and by third parties with whom we have a relationship, such as web analytics services and advertising network services. Cookies help us track and understand how individuals use and interact with our Site and Services and to otherwise help us manage our Site and Services.

You can control cookies through your browser setting and other tools. For more information on the cookies, we collect and how to disable them, please visit our Detailed Cookie Use Notice.

Cross-device tracking: Connex Intl uses data analytics companies, advertising networks, social media companies, and features offered by Google Analytics services or pixels such as from Facebook to engage in “cross-device tracking,” which occurs when platforms, publishers, and advertising technology companies try to connect an individual’s activity across smartphones, tablets, desktop computers, and other connected devices. The goal of cross-device tracking is to enable companies to link an individual’s behavior across devices.

5. HOW WE SHARE PERSONAL INFORMATION

When you use our Services: When you use Connex Services to conduct a meeting, we may provide some Personal Information about each participant to you as the meeting moderator as well as to other participants in your meeting.

Our Service providers: We use third-party service providers, independent contractors and other affiliates that perform functions on our behalf. Examples include to perform credit card payment processing, marketing and advertising, order processing, and analyzing data. We share Personal Information described above including your contact details and financial information with these third-parties solely for the purpose of providing and improving our Site and Services. We only provide these entities with the Personal Information necessary for them to perform these services and functions on our behalf and they are bound by their contract with us to treat all Personal Information as confidential and to protect Personal Information from unauthorized access, use, or disclosure.

Other third parties: We share Personal Information with unaffiliated third-parties (including social media platforms and apps), agents, and/or independent contractors who help us maintain our Site and Services and provide other services including, but not limited to customer service, data analytics, marketing and advertisement, customer communications, research and surveys, contests, sweepstakes and other promotions. We seek to ensure that those third-parties will use Personal Information solely for the purpose of providing the services for which they are responsible. Our Site and Services use social plug-ins by the following providers, which may or may not be available to you based on your location:

  • Twitter
  • Linkedin
  • Facebook

Legal needs: We may disclose Personal Information: as required by law, such as to comply with a subpoena or similar legal process; when we have a good faith belief that disclosure is necessary to protect our rights or property, protect your health and safety or the health and safety of others, investigate fraud, or respond to a government request, or to allow us to pursue available remedies or limit the damages that we may sustain.

Reorganization, merger or other sale or transfer: We may also disclose Personal Information in connection with a merger, acquisition or sale of all or a portion of our business or assets (including in connection with any bankruptcy or similar proceedings).

Aggregate and De-Identified Information: We may share aggregate or de-identified information about users of our Site and/or Services with third parties for marketing, advertising, research or similar purposes.

6. THIRD-PARTY LINKS

Our Site and Services may contain links to other third-party sites that we do not own or control, such as social networking sites listed in Section 5 above, or third-party analytics tools that collect information about visitor traffic on our Sites and Services. This Privacy Notice does not address nor do we control or have responsibility for the policies or practices of any third parties or any third-party sites to which our Site or Services link. If you provide any information to such third parties, different rules regarding the collection and use of Personal Information may apply.

The providers of third-party apps, tools, widgets and plug-ins on our websites and apps, such as the Facebook ”Like“ button, also may use automated means to collect information regarding your interactions with these features. This information is subject to the privacy policies or notices of these providers. Please review the third party’s privacy policies before providing any Personal Information to them.

7. HOW WE PROTECT PERSONAL INFORMATION

Connex maintains reasonable organizational, physical, technical, and administrative safeguards to protect the confidentiality, security and integrity of Personal Information including end to end encryption and need to access to Personal Information.  The Personal Information that we collect is stored in secure operating environments that are not available to the general public.  Nevertheless, we remind you that no security measure is perfect and Connex cannot guarantee the security of any information provided over the Internet. In addition, the other websites that you may access through your use of the Connex Site or Services may have different security practices and you should review the notices, policies, and practices at those other websites.

You should take steps to protect against unauthorized access to your password and devices by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, changing your password over time, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity, except where otherwise required by applicable law.

8. HOW LONG WE KEEP PERSONAL INFORMATION

We retain Personal Information for the period necessary to fulfill the purpose outlined in this Notice which in general regarding your use of our Services can be as short as 30 days, unless a longer retention period is required or permitted by applicable law.

We may also retain your payment information for recordkeeping purposes and/or to complete transactions (e.g., when you make a payment), and you may not be able to change or delete the Personal Information you provided until after completion of such payment. For more information on how to close or delete your account, please visit Section 10 below.

9. CHOICES YOU HAVE ABOUT HOW WE USE AND DISCLOSE PERSONAL INFORMATION

Transactional emails: We occasionally send transactional emails notifying you about your orders, account information, changes to our Services, updates to our online documents, and other matters as required by law. You may not opt out of transactional emails.

Commercial marketing emails: We may send you marketing communications from time to time. If you are in the EU/EEA/Switzerland/UK and you are our current or former customer, we may send you commercial marketing emails relating to products or services similar to those which have been previously purchased by you. You can also opt in to receive from us other types of commercial marketing communications. Regardless of your location, you can always manage your communication preferences, including unsubscribing, by clicking the appropriate links included at the bottom of each email, , or by contacting us at policy@connexintl.com

Traditional marketing by postal mail: Depending on where you live, you may receive marketing communications from us by postal mail. You can stop these communications by contacting marketing@connexintl.com.

Third-party marketing, advertising, and other communications: You can opt in to receive marketing, advertising and other email communications from our partners, vendors, or affiliates. If you do opt in, you will be subject to the third party’s separate privacy notice, and you are responsible for managing your email preferences according to that privacy notice. Some marketing and advertising companies may collect Personal Information about your use of our Site or Services through cookies, web beacons, and other technologies so they can market products or services to you, monitor the ads served to your browser, and learn which webpages you viewed when ads were delivered. To learn more about interest based advertising and your choices, please click here. We are not responsible for marketing emails sent by our partners and other third parties, and you need to visit their webpages for instructions on how to stop e-mails from them.

Push notifications: You can opt out of receiving push notifications using your mobile application or device settings. Opting out of push notifications may impact the functionality of our Services.

Interest-Based Advertising Out-Opt Tools: Google and Facebook offer opt-out features that let you opt out of using Personal Information about you for interest-based advertising:

Google: You may prevent Personal Information about your from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add On. You can opt out of Google Analytics by following the instructions per Google.

Facebook: About Facebook Ads and Privacy Facebook

You can also learn more about the options available to you to limit third party advertisers that use tracking or targeting tools in connection with our Site or Services:

Do not track: Currently we do not alter our data collection and use practices in response to Do Not Track signals.

10. HOW TO MANAGE OR DELETE PERSONAL INFORMATION ABOUT YOU

Information that you provide during registration of your moderator or participant account may be available in the Connex online client interface. You must enter your user name/email address and password to access your account.

Updating account information: You may correct, amend or update profile or account information at any time by adjusting that information in your user profile. If you need further assistance correcting inaccurate information, please contact us at policy@connexintl.com.

Account closure: You can close your Connex account at any time by email us at policy@connexintl.com. If you request to close your account, we will disable all access to your account. Your account information will not be accessible to you, but we will archive your account in case you want to rejoin or re-activate your account in the future.

Account deletion: If you request to delete your Connex account, we will remove Personal Information from your account. Your account will not be accessible to you even if you choose to rejoin or reactivate your account at a later date.

Please note however, that Personal Information necessary for the purposes of maintaining business records regarding a deleted or cancelled account, including records of credit transactions and account ownership, will be retained in accordance with applicable law. Please see Section 8 regarding our data retention practices for more information.

You can request to delete your Connex account by contacting us by email at policy@connexintl.com.

11. FOR CALIFORNIA RESIDENTS

This Privacy Notice for California Residents supplements the information contained in Connex’s Intl’s GENERAL PRIVACY NOTICE above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to workforce-related Personal Information collected from California-based employees, job applicants, contractors, or similar individuals.

Where noted in this Notice, the CCPA temporarily exempts Personal Information reflecting a written or verbal business-to-business communication (“B2B Personal Information”) from some its requirements.

11.1. CCPA Personal Information Collected

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information“). Personal Information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

  • Identifiers: such as your name, postal address, email address, credentials to access your Connex Intl account, social media handles, and, when you visit our Sites, use our Services or interact with widgets or plug-ins, Internet Protocol address and/or unique device identifier;
  • Other categories of Personal Information described in Section 1798.80(e): including the Personal Information listed in the preceding bullet as “identifiers”, telephone number, employment, payment information and other information that identifies, describes, or is reasonably capable of being associated with, a particular consumer;
  • Protected Classifications under California or federal law: such as age (40 years or older), gender, etc.
  • Commercial information: including Services purchased, and information about consumer preferences and behavior that we collect from you;
  • Internet/electronic activity: including but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our Sites and Services;
  • Geolocation data: if you participate in our Services or it is publicly available;
  • Sensory information: including audio recordings when you participate in our Services or call our customer service telephone number(s); and
  • Inferences drawn from other Personal Information: including for interest based advertising reflecting a consumer’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities and aptitudes and/or if you apply for a job with us.

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Site
  • Service providers and other third parties including our clients, social media platforms, and third-party partners such as analytics partners or others. For more information, please see Section 1 above.

11.2. Purposes for use of CCPA Personal Information.

We may use, or disclose the Personal Information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide Personal Information to purchase a service, we will use that information to process your payment and facilitate delivery. We may also save Personal Information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Site and Services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Site, Services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Site and Services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting Personal Information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users and/or CCPA consumers is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. For more information about the purposes for which we collect and use Personal Information we collect regarding California consumers, please see Section 3 above.

11.3. Disclosure of CCPA Personal Information

In the preceding twelve (12) months, we have disclosed CCPA Personal Information for a business purpose, including to the following categories of third parties:

Categories of CCPA Personal Information and Categories of Third Parties

 Identifiers
(e.g., real name, address, email address, telephone number, or other similar identifiers)

  • Payment processors
  • Our clients
  • Advertising networks
  • Data analytics providers
  • Social networks

Other categories of CCPA Personal Information described in Section 1798.80(e) (e.g., including the CCPA Personal Information listed above as “identifiers”, telephone number, payment information and other information that identifies, describes, or is reasonably capable of being associated with, a particular consumer)

  • Payment processors
  • Our Clients
  • Advertising networks
  • Data analytics providers
  • Social networks

Protected Classifications
(e.g., age (40 years or older), gender, etc.)

  • Data analytics providers

Commercial Information
(e.g., products or services purchased, obtained, or considered, or other purchasing histories or tendencies)

  • Payment processors
  • Advertising networks
  • Data analytics providers
  • Social networks
  • Government or law enforcement

Internet or other similar network activity
(e.g., browsing history, search history, information on a consumer’s interaction with a website)

  • Payment processors
  • Advertising networks
  • Data analytics providers
  • Social networks
  • Government or law enforcement

Geolocation data

  • Payment processors
  • Our clients
  • Advertising networks
  • Data analytics providers
  • Social networks

Sensory data
(e.g., audio recordings when you participate in our Services or call our customer service line(s))

  • Our clients
  • Government or law enforcement

Inferences drawn from Personal Information
(e.g., interest-based advertising profile reflecting a consumer’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes)

  • Advertising networks
  • Data analytics providers

For more information regarding the third parties with whom we disclose Personal Information for a business purpose please see Section 5 above.

11.4. Your CCPA rights and choices.

The CCPA also provides you (California Residents) with specific rights regarding Personal Information relating to you. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of Personal Information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • If we sold or disclosed Personal Information about you for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).

The information that we will provide to you will be masked, meaning that portions of it will be omitted so that it can’t be used fraudulently. For example, your telephone number may display as (123)-XXX-4567. Once we have verified your identity, we will disclose the specific pieces of Personal Information we collected about you, which will be made in writing and delivered through your account with us, if you maintain such an account.

We do not provide a right to know or data portability disclosure for Business-to-Business (B2B) Personal Information.

Right to Delete: You have the right to request that we delete any Personal Information that we collected from you and retained, subject to certain exceptions. Please note that if you delete Personal Information about you, some of our Services may not work the same.

Once we receive your request and confirm your identity we will review your request to see if an exception allowing us to retain the Personal Information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for Business-to-Business (B2B) Personal Information.

Right to opt out of sale of Personal Information: You have the right to opt out of the sale of Personal Information, as defined in the CCPA. The term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest-based advertising or other data uses described in the “Cookies and Other Technologies” Section above, we will comply with applicable law as to those activities. You can read more on our Detailed Cookie Use Notice

To opt out of receiving interest-based advertising, you can exercise your choice by using your device’s or browser’s privacy settings.

Non-discrimination: We will not discriminate against you for exercising any of your privacy rights under CCPA or applicable law, including by, denying you goods or services, charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, providing you a different level of quality of goods or services, or suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.

11.5. Exercising your CCPA Rights to Know or Delete  

To exercise your rights to know or delete described above, you can:

  • Call us at 800.426.6639 Toll-Free (US);
  • Visit our website at www.connexintl.com/privacy-notice
  • Email us at policy@connexintl.com. When you email us:
    • Include “My California Rights” in the subject of the email
    • Please include sufficient Personal Information about you for us to locate your records and to verify the identity affiliated with your account. At a minimum, you must provide the full name and email address affiliated with your account. We may request additional Personal Information, such as your telephone number, account number, billing address if you have made a purchase with us, telephone number, or information regarding your order history, to complete the verification process if we are unable to verify your identity. Our ability to locate Personal Information about you is limited by the accuracy and the completeness of the information that you provide.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information you provide in a verifiable consumer request to verify the requestor’s identity or authority to make the request. You may receive follow-up communications from us requesting additional information that will help us match your identity with the Personal Information we maintain about you. For example, if there is a discrepancy between the Personal Information in our systems and the information you provided with your request, we may ask that you submit additional information to validate your identity such as your order history or other contact information (e.g., e-mail address, telephone number, billing address) you may have used to order products or use our services.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

If you do not have any account with us and want to submit a request to know or delete Personal Information, contact us at policy@connexintl.com or call us at 800.426.6639.We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.

Only you, or someone legally authorized to act on your behalf (an “Authorized Agent” may make a request to know or delete related to Personal Information about you.  An Authorized Agent can be a third party that you authorize to act on your behalf, such as a third party with power of attorney.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact policy@connexintl.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

11.6. California Shine the Light

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to policy@connexintl.com or write us at Connex Intl, 46 Federal Road, Suite F Danbury, CT 06810

11.7 Changes to this CCPA Privacy Notice

We reserve the right to amend this CCPA Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on this Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

11.8 CCPA Contact Information

If you have any questions or comments about this notice, the ways in which Connex Intl collects and uses Personal Information about you described here and in our General Privacy Notice above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 800.426.6639
Website: www.connexintl.com/privacy
Email: policy@connexintl.com
Postal Address:

Connex Intl
Attn:  Privacy Specialist
46 Federal Road, Suite F
Danbury, CT 06810

We firmly believe that the internet should be available and accessible to anyone, and are committed to providing a website that is accessible to the widest possible audience, regardless of circumstance and ability.  With this in mind, we have installed accessiBe for our website visitors.  For our complete Accessibility Statement click here.  If you are experiencing technical difficulties with this plugin, please email policy@connexintl.com  or call us at 800.426.6639.

12. FOR INDIVIDUALS IN THE EUROPEAN UNION (“EU”)/ EUROPEAN ECONOMIC AREA (“EEA”)/SWITZERLAND/UK

Under applicable law and regulations, you may, at any time, exercise certain rights, including the following:

Access: The right to request access to Personal Information about you, which includes the right to obtain confirmation from us as to whether or not Personal Information about you is being processed, and where that is the case, access to the Personal Information and information related to how it is processed.

Rectify or erase: The right to rectification or erasure of Personal Information about you, which includes the right to have incomplete Personal Information completed;

Restrict: The right to obtain a restriction of processing concerning Personal Information, which includes restricting us from continuing to process Personal Information about you under certain circumstances (e.g., where you contest the accuracy of the Personal Information, for a period enabling us to verify the accuracy of the Personal Information);

Object: The right to object to the processing of Personal Information about you under certain circumstances, including objecting to processing Personal Information for direct marketing purposes, or objecting to processing Personal Information when it is done based upon legitimate interests;

Data portability: The right to data portability, which includes certain rights to have Personal Information about you transmitted from us to another controller; and

Consent: Where data processing is based on your consent, the right to withdraw your consent at any time.

If you think we have not complied with a data protection law, you may also have the right to lodge a complaint with a supervisory authority, a list of which is available at https://edpb.europa.eu/about-edpb/board/members_en. We would, however, appreciate the chance to deal with your concerns before you approach any authority so please contact us first.

If you want to exercise one or more of the above rights, you can contact us at policy@connexintl.com We will respond within a reasonable timeframe and in any case as required by applicable law.

13. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

The Personal Information and other information that we collect from you will be transferred to, and stored in the United States. It may also be processed by staff operating outside the EU/EEA/Switzerland/UK who work for us or other entities acting as data processors processing data on our behalf. This includes staff and providers engaged in, among other things, the fulfillment of your request or order and the provision of support services. More information on to whom Personal Information about you is disclosed can be found in Section 5 above.

Your Consent to International Transfer of Personal Information

If you are located in the EU/EEA/Switzerland/UK we may also process, store, and/or transfer Personal Information we collect about you, in and to a country outside the EU/EEA/Switzerland or UK including the United States. Those other countries may have different privacy laws that may or may not be as comprehensive as your own.

By submitting Personal Information or engaging with our Site and/or Services, you consent to this transfer, storing, and/or processing.

Notice Re: CJEU Schrems II Ruling

On July 16, 2020, the European Court of Justice Schrems II decision placed additional compliance requirements on the use of EU Standard Contract Clauses (SCC) for transfer of EU/EEA Personal Information to the U.S. by companies subject to Section 702 of the U.S. Foreign Intelligence Surveillance Act (FISA) and/or Executive Order 12333 (E.O. 12333).

We know our clients, website visitors, and business partners care deeply about privacy and data security; and we optimize our work to get these issues right. We’d like to confirm that you can continue to use our Site and Services regarding EU/EEA/Swiss/UK Personal Information in compliance with EU/EEA/Swiss and UK law.

First, please know that it is our good faith belief that the types of EU/EEA/Swiss/UK Personal Information we receive, collect, process, use and/or share in the U.S. are not of the types of Personal Information that would generally be subject to requests from U.S. government authorities pursuant to FISA Section 702 and/or E.O. 12333.

Second, please note that as part of our good faith efforts to comply with the EU GDPR and other applicable laws we also implement data encryption at rest and in transit, data minimization, and need to know access to Personal Information.

Third, our transfer to a third country may also be necessary in order to perform a contract with you or in individual cases for the purposes of our compelling legitimate business interests and in order to comply with our internal policy, contractual and legal obligations.

Trust is a top priority for us, and we will continue to work vigilantly to ensure that our clients, website visitors, and business partners are able to enjoy the benefits of our Site and Services securely, compliantly, and without disruption. As always if you have questions or concerns about our collection and/or use of Personal Information, please contact us at policy@connexintl.com or through your account.

14. CHANGES TO THIS PRIVACY NOTICE

We periodically update this Privacy Notice, and encourage you to review it each time you visit our Site or use our Services. We will notify you of any material changes made to the Notice and will post those changes through a prominent notice on our Site and Services, along with an update to the Effective Date. Depending on where you live, we may give you an opportunity to accept these changes prior to continuing on our Services. If you do not agree to any changes made to this Notice, you should stop using our Services.

15. CONTACT US

If you have any questions or concerns about our Privacy Notice or our privacy practices, please contact us at policy@connexintl.com  or mail us at: Connex Intl, ATTN: Privacy Specialist, 46 Federal Road, Suite F Danbury, CT 06810.

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