Privacy policy
June 3, 2024
Coffey Communications Inc. (“Coffey”) understands that you care about how we collect, use, and share information when you interact with our websites, social media sites and handles, and email (our “Services”) and we value the trust you place in us. This Privacy Policy explains:
- The types of information we collect through our Services.
- How we use and protect that information.
- The types of information we may share with others and under what circumstances.
- The choices you have regarding our collection, use, and sharing practices.
- Details regarding our use of third-party cookies and other tracking technologies.
This Policy applies when you interact with us through our Services. It also applies anywhere it is linked. It does not apply to non-Coffey websites and mobile applications that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.
Coffey provides communications and marketing services to our clients, and information that we process on behalf of our clients is covered by our clients’ privacy policies and our client agreements. Any questions or requests with regard to that information should be directed to our clients.
For questions about our privacy practices, contact us at:
Coffey Communications Inc.
1505 Business One Circle
Walla Walla, WA 99362-9421
Email: info@coffeycomm.com
Information We Collect
Information you give us: Some of the Services may include features or services that permit you to enter contact information and other information about you. We collect and store any information you enter on our Services. This includes:
- Contact information.
- Registration information when you sign up for our content management system (Site Assist).
- Payment information and associated contact information when engaging in a transaction on our Site.
- Information you volunteer when you respond to surveys.
- Email address when subscribing to our email bulletins.
- If you contact us, we may keep a record of that correspondence and any contact information provided.
- A third party is used for payment processing.
Information We Collect Automatically: When you interact with the Services, certain information about your use of our Services automatically is collected. Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. This includes:
- Details of your visits to our Site and information generated in the course of the use our Site (including the timing, frequency, and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our site.
- Details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system, and browser type.
- Information about how you interact with our ads and newsletters, including whether you open or click links in any correspondence.
Please see below for more information about how our automatic collection of information works.
If you are a client, then we may collect or have access to your account information with third parties to provide marketing, communications, and search engine optimization services, and the information that those third parties collect, such as analytics data.
How We Use and Protect Information About You
We may use the information we collect from you for the following purposes:
- To provide you with our products and Services, including to take steps to enter into a contract for sale or for services, process payments, fulfill orders, and send service communications.
- To provide you with the best service and improve and grow our business, including understanding our customer base and purchasing trends and understanding the effectiveness of our marketing and communications.
- To process your job application.
- To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and to comply with legal requirements regarding the provision of products and services.
How We Secure the Information We Collect from or About You
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of Site Assist, systems, servers, devices, and databases we operate or that are operated on our behalf.
Our Sharing of Information About You
Service Providers: We engage vendors to perform functions on our behalf such as: website, software, and data hosting or storage; content management; database management; technical integration; marketing automation; analytics and site optimization; posting and accepting job applications; and payment processing. The categories of our service providers are:
- Billing and collection providers, such as payment processors.
- Auditing and accounting firms.
- Professional services consultants, such as firms that assist with providing legal services, or supplying project-based resources and assistance.
- Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
- Information technology vendors, such as entities that assist with website design, hosting, and maintenance, data and software storage, and network operation.
Social Media Platforms: Where you choose to interact with us through social media, your interaction with those platforms typically allows them to collect some information about you through digital cookies they place on your device and other tracking mechanisms. In some cases, the platform may recognize you through its digital cookies even when you do not interact with their application, such as when you are logged in to the platform and visit our website. Please visit the third parties’ respective privacy policies to better understand their data collection practices and controls they make available to you.
Third Parties Involved in Advertising: We partner with third parties who assist us in serving advertising and other communications regarding the Services to others who may be interested in the Services. These third parties may use tracking technologies on our website to collect or receive information from the Services and elsewhere on the internet and use that information to provide measurement services and target ads.
State or federal agency or other regulatory body: Security and privacy protections shall be implemented for the transfer of organizational records, or extracts of such records, containing sensitive personal information to a state or federal agency or other regulatory body that lawfully collects such information. Encrypted email or other methods of protected communication shall be utilized.
Additional Information About our Data Collection and Sharing Practices
Sharing of Aggregated Data: We may analyze aggregated, de-identified data and share these analyses at our discretion, including with marketing agencies, media agencies, and analytics providers. These third parties will not be able to relate this data to identifiable individuals.
Combination of Information: We may combine information from the Services together and with other information we obtain from our business records. Additionally, information collected about you from a particular browser or device may be linked to information collected from another computer or device that we believe relates to you.
Change of Ownership or Corporate Organization: We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
Cross-border Transfer of Data: If you use our Services outside of the United States, then you understand that we may collect, process, and store personal information about you in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. By using the Services, you consent to the collection, international transfer, storage, and processing of data about you.
Additional Security Requirements
Sanctions shall be fairly applied to employees following violations of the information security policies once a breach is verified and includes consideration of multiple factors. The organization documents personnel involved in incidents, steps taken, and the timeline associated with those steps, steps taken for notification, the rationale for discipline, and the final outcome for each incident. Details of all incidents shall be recorded via support ticket and also in CRM.
Your Options and Rights
If at any time you would like to unsubscribe from receiving future emails, then you can click the unsubscribe link at the bottom of any email bulletin, or email us at info@coffeycomm.com, and we will promptly remove you from all correspondence.
Health Information Privacy Obligations
Some of our clients are covered by the federal Health Insurance Portability and Accountability Act and its regulations (“HIPAA”). Sometimes, we handle health information on behalf of these clients. In situations when we may be a business associate of these clients, we will enter into business associate agreements and will comply with HIPAA with respect to HIPAA-covered health information.
Information about children
The Services are intended for users who are thirteen years old and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 13, we will delete that information. Please contact us with any concerns.
Changes to This Policy
We may make changes to this Policy from time to time. We will post any changes, and these changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes.
Additional Information About Our Use of Tracking Technologies and Interest-Based Advertising
Coffey relies on partners to provide many features of our Site and Services using data about your use of the Coffey Site and other sites. We use cookies for the following purposes:
- Site Operations: Enabling features that are necessary for providing you the services on our Site, such as identifying you as being signed in, tracking content views, and remembering your preferences.
- Analytics: Allowing us to understand how our Services are being used, track Site performance, and make improvements.
- Personalized Advertising: Delivering tailored advertising based on your preferences or interests across Services and devices and measuring the effectiveness of ads and other communications.
- Social Media: Enabling the sharing of content from our Services through social networking and other sites.
Below is a list of these partners with links to more information their use of your data and how to exercise your options regarding tracking.
|
Category |
Partner |
Further Information |
|
Analytics |
|
How Google uses information from sites or apps that use our services |
|
Analytics |
CrazyEgg |
|
|
Analytics |
Hotjar |
|
|
Analytics |
Lead Forensics |
Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, then some features of the Services may not be available, work, or work as designed. You also may be able to opt out of or block tracking by interacting directly with the third-parties who conduct tracking through our Services.
You can learn more about ad serving companies and the options available to limit their collection and use of information about you by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.
Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, then you also may delete your opt-out preferences.
Your browser or device may include “Do Not Track” functionality.
Your California Privacy Rights
“Shine the Light” Law
Residents of the State of California have the right to request information regarding third parties to whom we have disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, then please email info@coffeycomm.com or write to us at our address listed above.
California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, correct, delete, and limit disclosure of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.
Notice at Collection Regarding the Categories of Personal Information Collected
You have the right to receive notice of certain information about our data collection, use, and disclosure. The following table summarizes the categories of personal information we collect; the categories of sources of that information; whether we disclose, sell, or share that information to service providers or third parties, respectively; and the criteria we use to determine the retention period for such information. The table also summarizes the categories of “sensitive” personal information that we collect, the purposes for which such information is used, and whether we sell or share such information. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described above in “How We Use Your Information.”
|
Category |
Information Type |
Source |
We disclose to: |
We sell to/share with: |
|
Identifiers |
|
You; our social media pages; third party subscription service providers |
Service Providers |
Business partners |
|
Health Information |
|
You; our clients |
Service Providers |
Not sold/shared |
|
Financial Information |
|
You |
Service Providers |
Not sold/shared |
|
Commercial Information |
|
You |
Service Providers |
Not sold/shared |
|
Internet or Electronic Network Activity Information |
|
You; our analytics and advertising partners |
Service Providers |
Advertising partners |
We determine the retention period for each of the categories of personal information listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation.
Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement.
Entities to whom we “sell” or with whom we “share” information are third parties. Under the CCPA, a business “sells” personal information when it discloses personal information to a company for monetary or other benefit. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us. A business “shares” personal information when it discloses personal information to a company for purposes of cross-context behavioral advertising.
Your rights under the CCPA
- Opt out of sale or sharing of personal information: You have the right to opt out of our sale or sharing of your personal information to third parties. To exercise this right, please decline tracking of cookies or contact us. Your right to opt out does not apply to our disclosure of personal information to service providers.
- Know and request access to and correction or deletion of personal information: You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. You also have the right to request in certain circumstances that we correct personal information that we have collected about you and to delete personal information that we have collected directly from you. Please contact us to exercise these rights.
Special Information: Nevada Residents
Residents of the State of Nevada have the right to opt out of the sale of certain pieces of information about them to third parties who will sell or license their information to others. At this time, Coffey does not engage in these sales. If you are a Nevada resident and would like more information about our data sharing practices, then please email info@coffeycomm.com.
Making a request to exercise your rights
Submitting requests: You may request to exercise your rights by submitting the contact us form or making a request using the contact information above.
You may, under certain circumstances, authorize another individual or a business, called an authorized agent, to make requests on your behalf.
We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Verification: We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity.
We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.