Oxbow Data Management Systems, LLC Website Privacy Policy
Effective Date: January 1, 2021
Introduction
Oxbow Data Management Systems, LLC (Oxbow), a subsidiary of McCallie, Inc, a subsidiary of Alutiiq, LLC, (“us,” “we,” or “our”) are committed to protecting the privacy of those who visit the Oxbow website. As such it is important for the Oxbow Team to let all our site visitors know that we do not collect Personal Information/Personally Identifiable Information (PI/PII) from those who visit the site by any means. Therefore, the Oxbow Data Management Systems, LLC Website Privacy Policy is relatively simple. We neither collect, sell, nor otherwise disclose PI/PII of individuals who visit this website.
The access to data and information we provide to website visitors by way of https://www.oxbowdms.com/ is referred to as the “Service”.
Definitions
· Service: Service is defined above.
· Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
· Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
· Cookies: Cookies are small files stored on your device (computer or mobile device).
Types of Data Collected
As you are probably aware, we collect several different types of information for various purposes to provide and improve our Service to you. PI/PII is not one of those types.
· Personal Data
o We will not ask for nor collect any PI/PII during your visit to our site.
· Non-PI/PII Data
o We do collect non-PI/PII data when you visit the site. We use the non-PI/PII data to improve the Service. By using the Service, you agree to the collection and use of Non-PI/PII in accordance with this policy. Non-PI/PII categories include Statistical, Usage, and Tracking Cookies. Each are discussed below.
· Statistical Data. To monitor use of the Site and improve its quality, we may compile statistical information concerning the use of the Site through analytics services. Examples of this information may include:
o The number of visitors to the Site, or to sections or pages within the Site
o Patterns of traffic flowing through the Site
o Length of time spent on the Site, or in sections or pages of the Site,
o The other sites that refer visitors to the Site
o The pages of the Site that visitors frequently use as entry and exit points
o Utilization of the browser and operating systems and versions used by visitors to the Site.
o The analytics services may transfer this information to Service Providers in case of a legal obligation or if a service provider processes data on behalf of that service.
· Usage Data
o We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
o While this information can be associated with the IP address belonging to the computer you used to visit the Site, it will not be associated with you as an individual.
· Tracking Cookies Data
o We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
o Cookies are files with a small amount of data which may include an anonymous unique identifier.
o Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used, such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
o You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
o Examples of Cookies we use:
§ Session Cookies. We use Session Cookies to operate our Service.
§ Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
§ Security Cookies. We use Security Cookies for security purposes.
Use of Data
· PI/PII Data: We do not collect PI/PII data from visitors to the website
· Non-PI/PII Data: We use the collected non-PI/PII data for various purposes:
o To provide and maintain our Service
o To notify you about changes to our Service
o To allow you to participate in interactive features of our Service when you choose to
o To provide customer support
o To gather analysis or valuable information so that we can improve our Service
o To monitor the usage of our Service
o To detect, prevent and address technical issues
Transfer of Data
Non-PI/PII collected from your visit may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data to the United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all the steps reasonably necessary to ensure that your non-PI/PII data is treated securely and in accordance with this Privacy Policy and no transfer the non-PI/PII data collected during your visit will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.
Disclosure of Data
It is our Corporate policy not to sell PI/PII collected from customers, clients, employees, shareholders, contractors, subcontracts, or consultants. Similarly, we do not exchange or trade personal information for any non-financial consideration. Regardless, this website does not collect PI/PII in any way.
In the unlikely event that your PI/PII is incidentally captured, we will not disclose the information we collect through this Site except with your consent or as described in this Policy. We may disclose your data and non-PI/PII data collected from the site for the same reasons that we may use it as described in this Policy, which includes disclosing it to our affiliates and non-affiliated entities, as we deem necessary to carry out those purposes.
Service Providers. We may need to use or disclose this information with our Service Providers:
o As you direct in the unlikely event PI/PII is collected
o To manage the Site
o To enhance our services by, among other methods, obtaining assistance with providing more personalized services to you through analytics and other technologies.
o To protect our interests and legal rights, such as through responding to subpoenas and defending litigation; and
o To protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications) and claims and other liabilities.
We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data.
Legal Process, Security, Defense, Protection. In the unlikely event that PI/PII related to you is collected, it is possible that we will need to use or disclose information about you if required by law, subpoena, or other legal process. Additionally, we may disclose information about you if we have a good faith belief that disclosure is reasonably necessary to:
o Demonstrate our relationship with you
o Investigate, prevent, or take action regarding suspected or actual illegal activities or to assist law enforcement agencies
o Protect the security or integrity of the Site
o Investigate and defend ourselves against any third-party allegations or claims
o Protect the rights and safety of others
Change in Control or Sale. We may share, sell, assign, or license your PI/PII, if collected, in connection with certain business transactions, such as a sale, acquisition, merger, or change in control of the Company, or in preparation for any of these events. In such cases, we will take appropriate steps under the circumstances and to the extent possible to ensure that the recipient will apply privacy protections substantially similar to those established by this Policy. Any entity that acquires all or substantially all of the Company’s assets will have the right to continue using your data consistent with this Policy or as otherwise agreed to by you.
In no case will we sell or license your PI/PII, if collected, to third parties, except as set forth above or as required or permitted by law.
Social Media Plugins
This Site does not use social media plugins.
Security of Data
No system for safeguarding personal or other information is 100% secure and even though we have taken steps to protect any personally identifiable information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information. However, we take a number of steps to safeguard the security of personally identifiable information obtained through the Site. For example, we maintain administrative, technical and physical controls to reasonably safeguard data from unlawful use, unauthorized access or disclosure. Additionally, we use Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our Site. Individuals who have access to confidential and otherwise nonpublic data are required to maintain the confidentiality of such information.
Service Providers
We may employ other companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used.
In the unlikely event that your PI/PII is incidentally captured, Service Providers may have access to your Personal Data in order to perform these tasks on our behalf. They are obligated not to disclose or use it for any other purpose.
Analytics
We may use Service Providers to monitor and analyze the use of our Service.
· Squarespace Analytics
o Squarespace Analytics is a web analytics service offered by Squarespace that tracks and reports website traffic. Squarespace uses the data collected to track and monitor the use of our Service. This data is shared with other Squarespace services. Squarespace may use the collected data to contextualize and personalize the ads of its own advertising network.
o For more information on the privacy practices of Squarespace, please visit the Squarespace Privacy Terms web page.
Links to Other Sites
We may provide links to websites or resources outside of our Site for your informational purposes only (i.e. Twitter and Facebook). You acknowledge and agree we are not responsible for the availability of such sites or resources, and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through or provided by such sites or resources. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of any of your personal information that you provide or may be collected by such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.
Children’s Privacy
The Site is not directed to children as the products and services on this Site are intended for persons 18 years of age and older. Oxbow Data Management Systems, LLC does not knowingly collect, use or disclose any personally identifiable information from children. If you are concerned about your child’s use of the Site, you may use web-filtering technology to supervise or limit access to the Site.
If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers. If you are concerned about your child’s use of the Site, you may use web-filtering technology to supervise or limit access to the Site.
Changes to This Privacy Policy
Changes to this Policy. We reserve the right to change this Policy at any time. In the event we make material change(s) to the Policy, they will be effective immediately upon posting to the Site and will apply after the effective date listed above. You understand and agree that your continued use of the Site after the effective date, means that the collection, use, and sharing of your information collected after the effective date is subject to the updated Policy.
In the event the policy regarding sale of PI/PII were to change, you would be afforded the opportunity to opt-out of the sale of your company data or PI/PII in advance of any such action.
Applicable law
This Policy is governed by the internal substantive laws of the State of Nebraska, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within Nebraska. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.
California Residents
If you are a California resident, please read the following:
· General. This section of the Policy (CA Policy) supplements and amends the information contained in our Policy, with respect to California residents. This CA Policy applies solely to individuals, visitors, users, and others who are natural persons and residents of the State of California (“consumers” or “you”). The CA Policy is written to clearly state that we neither collect, use, or disclose Personal Information (PI) about you or relating to you. This CA Policy is adopted in part to comply with the California Consumer Privacy Act (“CCPA”). Any terms defined within the CCPA have the same meaning when utilizing within this CA Policy. The other provisions of the Policy continue to apply except as modified in this CA Policy.
· Information We Collect. We do not collect, use, or disclose personal information in any category identified in the CCPA from individuals visiting this site.
· Consumer Rights. Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their PI.
o Right to Request Deletion. As we do not collect, use, nor otherwise disclose personal information in any category identified in the CCPA from individuals visiting this site it is not necessary for you to request the Company delete your PI from the Company’s records or direct any service providers to delete your PI from their records. This in no way diminishes your rights under the CCPA.
o Right to Request Information. As we do not collect, use, nor otherwise disclose personal information in any category identified in the CCPA from individuals visiting this site it is not necessary for you to request the Company disclose the types of collected PI. This in no way diminishes your rights under the CCPA
o Right to Request Information as to Sale or Disclosure for Business Purpose. As we do not collect, sell, nor otherwise disclose PI of persons visiting the site it is not necessary for you to request information as to Sale or Disclosure for Business Purpose of PI. This in no way diminishes your rights under the CCPA.
o Right to Opt-Out. Oxbow Data Management Systems, LLC does not collect, sell, nor otherwise disclose PI of persons visiting the site. As such you have no need to request to “Opt Out” as we will not sell yours or anyone’s PI.
o Nondiscrimination. As we do not collect PI from visitors and as such, we provide the same level and quality of services from our site as required by the CCPA.
· Submitting Consumer Rights Requests. While we do not collect, sell, nor otherwise disclose PI of individuals visiting the site, it does not diminish your rights under the CCPA. As such, you may submit Consumer Rights requests regarding the above by contacting our parent company, Alutiiq, LLC, at 888-232-9574 or privacy@alutiiq.com. We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is:
o the consumer who is the subject of the request,
o a consumer on behalf of the consumer’s minor child, or
o by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.
· Identify Verification. If the Company requests, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a consumer. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt, but we may require an extension of up to forty-five (45) additional days to respond and we will notify you of the need for the extension.
How to Contact Us
At any time, you may contact our Parent Company, Alutiiq, LLC, with questions or concerns about this Privacy Policy at privacy@alutiiq.com. Written responses may also be submitted to:
Alutiiq, LLC (Attn: Privacy Officer)
3909 Arctic Boulevard, Suite 500
Anchorage, AK 99503
Phone: (907) 222-9500
Fax: (907) 222-9501