Privacy Policy

1. PURPOSE

The purpose of this Privacy Policy (the “Policy”) is to provide CBTS Technology Solutions LLC and its US subsidiaries, OnX Enterprise Solutions Ltd., and its subsidiaries, CBTS Technology Solutions UK Limited, CBTS Technology Solutions Ireland Limited, and CBTS Technology Solutions India LLP (“CBTS”, “our”, or “we”) customers, suppliers, employees, and the general public (collectively “you” or “your”) a comprehensive description of our online and offline practices regarding our collection, use, disclosure, and retention of personal information that we collect from you when you visit our website and in connection with any products and/or services you obtain from us.

2. SCOPE

This Policy applies to your information, including personal information, which we collect from you when you visit our website and in connection with any products and/or services you obtain from us. This Policy describes the types of information we may collect from you or that you may provide when you visit www.cbts.com or www.onx.com (collectively, our “Website”). It also describes our practices for collecting, using, maintaining, protecting and disclosing that information.

WHEN YOU ACCESS OUR WEBSITE OR USE OUR PRODUCTS OR SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP ACCESSING OUR WEBSITE.

BACK TO TOP

3. POLICY

We keep this Policy posted on our Website and you should review it frequently, as it may change from time to time without notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy. Your continued use of our Website following the posting of a new Privacy Policy indicates your acceptance of the new Policy. If at any point we decide to use your personally identifiable information in a manner materially different than what was stated at the time it was collected, we will notify you of this change by e-mail to the last e-mail address provided to us. You will have a choice (by means of an “opt out” opportunity) as to whether or not we use your information in this different manner. We will use information in accordance with the Privacy Policy under which your information was collected if you opt out of the new policy.

BACK TO TOP

• Information you provide to us directly when you purchase our products or services, such as name, address, phone number, email address and credit card number;
• Information we collect about you when you visit our Website, use our services, or view our online advertisements, such as IP address, search terms, and Web pages you visit while on our Website;
• Information we collect about you from other sources, such as commercially available sources; and
• Information supplied by you to our Website, such as demographic information (e.g., age, gender, purchase preference, etc.).

We may also collect information from you when you register for our products and services by means other than through our Website. All the information we collect about you may be combined to help us tailor our services to you and other customers. The information we collect depends on what you do when you visit our Website. There are two types of information that we are likely to collect:

1. Information you give us: This is information we ask you to provide directly to us in the course of conducting business on our Website, and by which you may be personally identified, such as name, service address, telephone numbers, e-mail address, credit card number, social security number (“personal information”).In certain circumstances, we may request, allow, or otherwise provide you with an opportunity to submit your personal information in connection with a feature, program, promotion or some other aspect of our Website. For instance, you may:
   • Provide your name, mail/shipping/service address, email address, and phone number when registering with our Website, submitting webform inquiries, or using our services; or
   • Provide certain demographic information about yourself (e.g., age, gender, usage frequency, etc.) when participating in a survey or poll.
2. Information collected through Automatic Data Collection Technologies: As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
   • Details of your visits to our Website, including traffic data, location data, and other communication data,
   • Resources that you access and use on the Website,
   • Information about your computer and internet connection, including your IP address, operating system, and browser type,
   • Search terms you use on our Website,
   • Specific web pages you visit,
   • Duration of your visits,
   • Type of internet browser, and
   • Type of computer operating system you are using.

The information we automatically collect using these technologies is statistical data only and does not include personal information. We may use it by itself or associate it with personal information we collect in other ways or receive from third parties. We may also aggregate it with information we have obtained from other customers or other sources. We may, among other things, share this information with our affiliated companies, allow third parties to collect such information directly from you, and/or share it with third parties to achieve those objectives. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns,
• Store information about your preferences, allowing us to customize our Website according to your individual interests,
• Speed up your searches, and
• Recognize you when you return to our Website.

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, advertisement networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you visit our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

BACK TO TOP

We may use your information to provide the products and services you request, to tell you about our other services, and to manage our Website and services. We may share your information with one or several of our business partners to make an initial determination of the services you may need. We may also share your information to protect and defend the rights and property of CBTS. We use your information for the following business purposes:

• To present our Website and its contents to you;
• To provide you with the products and services you purchased;
• To allow us to properly maintain and communicate with you about those products and services and to make improvements or upgrades when necessary;
• To confirm that you are being properly billed;
• To provide you with technical support and system maintenance;
• To inform you of new products or services that may be of interest to you;
• To allow us to understand the use of, and identify improvements to, our services;
• To generate de-identified or aggregated data;
• To prevent fraud, including the unauthorized use of our services or violations of applicable policies and terms of service;
• To ensure our own compliance with state and federal laws;
• To notify you about changes to our Website or any products or services we offer or provide through it; and
• To respond to legal requests or as otherwise required by applicable law.

Additionally, we may use or disclose your information without your consent to protect our customers, employees, or property in emergency situations, or to enforce our rights under our terms of service and policies in court or elsewhere. Further, we may disclose your information where necessary to provide or conduct a legitimate business activity related to the services provided to you, or as required by law or legal process, as more fully discussed under Other Uses and Information below. Circumstances when we may disclose your information:

• We may share this information within CBTS to improve our services to you; and
• We may share your information with our agents and trusted business partners only when required for the specific and limited purpose of providing products or services to you that you have authorized, such as to our shipper in order to fulfill an on-line order.

You may opt-out from receiving future promotional information from us as set forth below in the Contact Information section.

If you create a business account with us and provide us with any of the above information for the purpose of conducting business, you authorize us to store your name, shipping/service address, email address, and credit card and billing information.

BACK TO TOP

We automatically receive and store certain types of information when you interact with us. We use cookies or web beacons (also called “clear figs” or “pixel tags”) to obtain certain types of information when your web browser accesses our Website. We use cookies and web beacons for login verification, session management, load balancing, and personalization to enhance your user experience.

A cookie is a small text file created by our Website and stored on your computer’s hard drive, memory, or web browser. It enables our systems to recognize your computer by the Internet Protocol (“IP”) address and to provide customized services. The use of cookies is standard in the industry and used on most websites. The use of certain cookies in your region may require your consent and you will be prompted, through a cookie management platform, to choose to provide it or not provide it. If you do not provide consent, those cookies will not be placed onto your device or utilized to collect specific information. Some cookie usage is essential for our Website to function properly. Cookies enable you to take advantage of some of our Website features. Should you decline or delete them, certain parts of our Website may not function properly. We use several different types of cookies on our Website, including:

Strictly Necessary or Functional Cookies:

• Necessary cookies facilitate the operation of our Website. Without the use of these cookies, portions of our Website will not function properly.
• Functional cookies are used to remember your preferences on our Website and to authenticate your identity. For example, we use functional cookies to manage our cookie consent management platform.

Cookies that require consent in some regions (e.g., the EU/EEA):

• Performance Cookies. These cookies monitor the performance of our Website and how users interact with them. These types of cookies collect information such as how often users visit our Website, what pages they visit when they do, and what other websites they used prior to coming to our Website. These cookies also provide us with information that allows us to improve our Website and services.
• Behavioral Advertising Cookies. We may use behavioral advertising cookies in order to provide you with advertising tailored to your professional interests when you visit websites on and off our network. These cookies analyze information about your interests and your browsing history and provide you with advertisements on and off our network that match these interests. Behavioral advertising is a type of advertising based on your web browsing activity over a period of time.

Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, or when an email has been opened, and to provide other information. Examples of information we collect and analyze in this manner include the IP address used to connect your computer to the Internet; computer and connection information such as browser type and version, operating system and platform; your activities on our Website, including what you view/search for, as well as the URL you come from and go to next (whether this URL is on our site or not); and cookie number.

We may now or in the future work with third parties, including third party advertising networks and website analysis firms, who use cookies and web beacons when you visit our Website and third party sites. The information collected is often used by these advertising networks to serve you with personalized or interest-based advertisements or other messages while you are on our Website and/or on third party sites that better reflect your preferences and needs.

Certain browsers may offer you the option of providing a Do Not Track Notice (“DNT Notice”) if you do not want your online activities tracked for preference-based advertising purposes. Some browsers are, by default, set to provide a DNT Notice, whether or not that reflects your preference. Providing a DNT Notice serves as a means to ensure that cookies, web beacons and similar technology are not used for preference-based advertising purposes – that is, to restrict the collection of information about your online activities for advertising purposes. Unfortunately, given how preference-based advertising works, DNT Notices may not effectively accomplish this goal. For this and other reasons, with respect to our Website, we do not take any action based on browser based DNT Notices. Rather, if you do not wish to participate in preference-based advertising activities, you should opt-out as described above.

BACK TO TOP

In certain instances, we may communicate with you via email; for example, if you request a particular service or sign up for a feature that involves email communications, the email relates to a purchase you have made with us, sending you information about our other products and services, or you consented to being contacted by email for a particular purpose. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of each email we send, or as provided below, provided, we reserve the right to send you transactional emails such as customer service communications.

As we continue to develop our business, we may sell or purchase assets. If another entity acquires some or all of our assets, the information we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

We reserve the right to disclose any information about you if we are required to do so by applicable law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; or (c) protect or defend our legal rights, property, or other users.

BACK TO TOP

Californian Resident Rights

Under the CCPA, California residents have specific rights regarding their personal information.

• Right to Deletion: You may request that we delete any personal information about you that we collected from you.
• Right to Correction: You may request that we correct any inaccurate personal information we maintain about you.
• Right to Know: You have the right to request any of the following:
  • Categories of personal information we have collected from you,
  • Categories of sources from which your personal information is collected,
  • Business purpose for collecting, selling, or sharing your personal information with third parties for cross context behavioral advertising,
  • Categories of third parties to whom we disclose your personal information, and
  • Specific types of personal information that we have collected about you.
• Right to Receive Information About Onward Disclosures: You may request that we disclose to you the categories of personal information that we have disclosed, sold or shared about you, the categories of persons to whom we disclosed your personal information, and the categories of third parties to whom the personal information was sold or shared.
• Right to Opt-Out of the Sale and Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the sale and sharing of your personal information. You also have the right to limit the use of your sensitive personal information to the purposes authorized by the CCPA. However, to be clear, CBTS does not sell your personal information to third parties.
• Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights. CBTS will not deny you goods or services or charge you a different price or rate for goods or services for exercising your rights.
• Right to Limit Use of Sensitive Personal Information: CBTS also does not use or disclose sensitive personal data for any purposes that would require a user to exercise a right to limit according to California law.

These rights can be exercised directly or through an authorized agent by contacting us through the information found in the Contact Information section below.

What Data We Collect

For purposes of the CCPA “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. In the last twelve (12) months, we may have collected the following categories of personal information from you:

To exercise the access, disclosure, and deletion rights described above, please submit a verifiable consumer request contact us at the information below in the Contact Information section.

Data Retention

We retain your personal information for as long as reasonably necessary to fulfil the purposes described in this privacy notice. Data may be retained for up to two (2) years after it was last actively used. However, in some instances, we may need to retain your personal information beyond these retention periods due to regulatory requirements or in response to a regulatory audit, investigation, or other legal matter. These requirements also apply to our third-party service providers.

Californian Employees, Applicants and Contractors

If you are a CBTS job applicant, or a current or former CBTS employee, you may have different rights, which are subject to the Notice of Collection for California Employees, Applicants, and Contractors Policy made available to you internally or at the time you applied.

In addition to the above, this section discloses the rights under the General Data Protection Regulation (“GDPR”) and the GDPR as incorporated into UK law by the Data Protection Act 2018 and amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations of 2019.

• The Right to Access: You have the right to request copies of your personal data. We may charge you a small fee for this service.
• The Right to Rectification: You have the right to request correction of any information you believe is inaccurate. You may also request that we edit and update your inaccurate information.
• The Right to Erasure: You have the right to request erasure of your personal data, under certain conditions.
• The Right to Restrict Processing: You have the right to request that we restrict processing of your personal data, under certain conditions.
• The Right to Object to Processing: You have the right to object to the processing of your personal data, under certain conditions.
• The Right to Data Portability: You have the right to request that we transfer data that we have collected to another organization, or directly to you, under certain conditions.

If you make a valid request, we are required to respond to you in one (1) month. If you would like to exercise any of these rights, contact us at the information below in the Contact Information section.

Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties.  This right applies even if their personal information is not currently being sold. If you are a Nevada consumer and wish to exercise this right, contact us at the information below in the Contact Information section.

Commercial Electronic Messages and Canadian Anti-Spam Law (CASL)

You may sign up for our mailing list in order to receive promotions and other materials that may be of interest to you. From time to time, we may send you electronic messages (such as emails) containing targeted financial news, information, and special product or service offers. If you no longer wish to receive these types of electronic messages, you may opt-out by clicking the “Unsubscribe” link contained in any such message or by contacting us at the information below in the Contact Information section.

Access

We permit the reasonable right of access to your information. Upon written request and authentication of identity, we will provide you with access to your information under our control, subject to any legal requirements and applicable exceptions to the right of access. Where an access request is refused, we will notify you in writing and provide our rationale for refusal along with a list of next steps available to you.

Correction

As noted above, if you demonstrate the inaccuracy or incompleteness of your information, we will amend the information as required. If appropriate, we will send the amended information to third party service providers to whom the information has been disclosed.

Complaint to the Privacy Commissioner

Please note that if we are unable to resolve any privacy concerns you may have, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada or the appropriate provincial Information and Privacy Commissioner.

BACK TO TOP

We take the security of your information very seriously. We have implemented industry standard security measures to protect against the loss, misuse and alteration of the information under our control. To help ensure the confidentiality of your personal information, it is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you have finished using a shared computer.

CBTS uses industry standard practices to safeguard the confidentiality of your information, including firewalls and Secure Socket Layer encryption. CBTS treats all data collected as an asset that must be protected against loss and unauthorized access. We employ various security techniques to protect such data from unauthorized access by persons inside and outside the Company.

Please be advised, however, that while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your information. In the unfortunate event that your information (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, and applicable laws require notice, we will notify you by e-mail in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time, we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.

BACK TO TOP

The Website contains links to various other websites that we do not control or maintain. Please be aware that these other websites may have privacy policies that may differ from CBTS’s policies. CBTS assumes no responsibility for either the content that appears on linked websites or the privacy of the information you provide once you have linked to other websites. You should read the privacy policies of all third-party websites before submitting any personal information.

BACK TO TOP

CBTS is committed to safeguarding the privacy of our telecommunications information. This notice is to inform you of your rights and our practices regarding Customer Proprietary Network Information (“CPNI”). Federal law and FCC regulations give you a choice about how CBTS uses your account information. These rules are designed to protect your privacy rights as a customer. CBTS values our customers and meeting your communication needs is our top priority.

You have the right and CBTS has a duty to protect the confidentiality of Customer CPNI. CPNI is information that is not publicly available that we obtain when providing telecommunications services to you. CPNI includes things such as your types of services, number of telephone lines, usage, and calling and billing records. You have the right to authorize use or non-use of your CPNI.

How will you benefit from authorizing the use of CPNI?

We may use your CPNI, without further authorization from you, to offer you services of the type you currently buy from us and share it with other CBTS companies with whom you already have an existing service relationship. With your consent we will be able to offer you a full range of additional solutions tailored to your needs, such as other products and services.

Will CBTS protect the CPNI information if you allow us to use it?

Absolutely. Regardless of your decision, CBTS will keep your information confidential. Giving CBTS authorization allows us to further customize the services we can provide to you, our valued customer. Restricting our use of your CPNI for marketing purposes will not affect the provision of any CBTS products or services to which you subscribe.

How do you supply us with consent?

When you sign up for service, you automatically give CBTS permission to use your CPNI. You have the right to restrict CBTS from using your CPNI. You may opt-out at any time. To restrict use of your CPNI, contact your sales representative or as instructed with the Contact Information section below. Your instructions to us will remain in effect until you notify us otherwise.

BACK TO TOP

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to us by using our Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us as instructed in the Contact Information section below.

BACK TO TOP

You may contact us at privacy@cbts.com or (866) 712-8077 if you have questions about our Privacy Policy or wish to exercise your rights regarding any information you have provided us. In addition, should you wish to file a formal complaint, you may file a complaint with any local supervisory authority in your geographic region.

If you wish to opt-out from receiving future commercial email correspondence from us or wish to withdraw your consent to our sharing of your information with relevant copromotional partners, you should follow the unsubscribe instructions found in the email sent to you, or otherwise contact us at the email address above. We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Website.

BACK TO TOP

XI. Changes to our Privacy Policy

We keep our Privacy Policy under regular review and place any updates on this web page. This Privacy Policy was last updated on April 29, 2024.

BACK TO TOP

XII. Cookie List

BACK TO TOP