Privacy Policy

Last updated January 1, 2018

PRIVACY STATEMENT

Coley & Associates, Inc. & subsidiaries (“Coley” or “we”) understand the importance of maintaining the confidentiality of your personal information and is committed to safeguarding the privacy of the users (including individuals and organizations) of our Coley’s Web sites. Please read the following information which outlines our commitment to privacy and how Coley will treat your personal information as you use this site.

PRIVACY POLICY

Coley provides this Privacy Policy to inform our websites’ users, requesters of products and services information, event registrants and participants, Coley news, promotion participants, users of our services and others (collectively referred to as “customers” or “you”) about our practices regarding collection, use, and disclosure of personally identifiable information (“personal data”) that we collect through our websites and services (collectively, “Services”).

We will not share or sell your personal information with third parties. While Services may include links or references to non-Coley websites, materials, or entities, this Privacy Policy does not apply to those non- Coley sites, materials, or entities unless otherwise indicated.

YOUR CONSENT

You should read this entire Privacy Policy before submitting information to Coley or using any Services. Whenever you submit information via the Services or otherwise to Coley, whether online or offline, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.

INFORMATION COLLECTION AND USE

Coley may collect personal data from customers both online and offline. In many cases, such information will be collected directly from you, such as through a transaction or inquiry, or your submission of a form, registration, or communication to us. Information may also be gathered from third-party sources (including without limitation, opt-in lists, publicly available data, consumer reporting agencies, other companies, and referrals) and through your activities and interactions with us. We may combine data collected from these disparate sources.

Coley collects personal data about its customers in a number of ways. While we have tried to be complete, this list is not necessarily exhaustive, given that these activities can vary from time to time.

The types of personal data typically collected by Coley may include the following, depending on your activities:

• Contact information, including name, title, street address (work), postal code, country, telephone numbers (work, cell, etc.), email address (work), company name, and other similar information.
• Employment information if applicable, (desired specialty, title, career objective, geographic location, compensation).
• Information in the form of audio, video, or photographs, whether submitted via the site or otherwise, such information will only be used for its intended purpose and will not be we shared with or distributed to a third party without the written permission of User.
• In the event you are submitting payment for a product or service, Coley will collect credit card information that will be shared and stored with third party processors, such as Authorize.net and/or other gateway processors. Coley does not retain the credit card information in its computers or databases.
• User content, including information provided when you use one of our online communities, forums or other online means of communications, and all other user submissions and content you provide.

ADDITIONAL INFORMATION

As you use our Services, some information can be “passively” collected using various technologies, such as cookies, web beacons, and navigational data collection (clickstream, log files, server logs, etc.). Your Internet browser automatically transmits some of this information, such as the URL of the website you just visited and the Internet Protocol (IP) address and browser version currently being used by your computer. Such technologies help us to keep track of your interactions with our Services, and provide you with a more customized experience, and may include referring/exit pages, platform type, date/time stamp, and number of clicks.

As is the case with many websites, Coley websites may use cookies and other automated information collection means. Cookies are small text files which are sent to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies act as a memory for a website, allowing that website to remember your device on your return visits. Cookies can also remember your preferences, improve the user experience as well as tailor the adverts you see to those most relevant to you. You can find more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them at www.aboutcookies.org.

We use both session cookies (which exist only until you close your web browser) and persistent cookies (which exist for a longer, specified period of time) on this website. The type of cookies used on our website can generally be put into three categories: Strictly Necessary, Performance/Analytics and Functionality. Strictly Necessary cookies on our website are essential in order to enable you to move around the website and use its features. These cookies don’t gather information about you that could be used for marketing or remembering where you have been on the internet. Performance/Analytics Cookies on our website collect information about how visitors use the website. For example, these cookies collect information about which pages visitors go to the most often, and if visitors get error messages from web pages. These cookies don’t collect information that identify a visitor. Information collected by performance/analytics cookies is aggregated and anonymous and only used to improve how our website works. Functionality cookies allow our website to remember choices you make and provide enhanced, more personal features to you.

The use of cookies by our service providers are not covered by our privacy statement. We do not have access or control over these cookies. Coley websites may also use IP addresses for the same purposes identified above, as well as to analyze trends, administer the website, track users’ movements, gather broad demographic information for aggregate use and to confirm that a particular individual affirmed his/her consent to specific legal terms (e.g. our clickwrap license agreement).

We may use web beacons (also known as Internet tags or clear GIFs) on our Services to access and set cookies and otherwise help us to better understand how users are utilizing our websites. Information provided by the web beacon includes the computer’s IP address, the type of browser being used, and the time that the web beacon was viewed. We may also use web beacons in emails and newsletters so that we know when such communications have been opened and to otherwise help us tailor our communications to individual users.

Coley uses personal data about customers for a wide range of purposes. We use it to respond to your requests (including requests for newsletter subscriptions, materials, support, and so on); to provide products or services that you have ordered; to process your order transactions and contact you regarding your order; to provide materials you have requested; to invite and help you participate in online and offline events, and/or activities; to allow you to post information and other content online (including in response to other postings); to improve our products, services, and websites; to follow up with you after you have communicated with us or submitted information to us; to send promotional communications or offers (unless you have requested that we not send such communications); for marketing and research purposes; for internal and/or external training, quality assurance, and other purposes (including without limitation, call center recordings); to allow you to contact another person; for legal and contractual reasons; to address your interests and concerns; and as otherwise specified in this Privacy Policy and/or at the point of personal data collection.

We may disclose personal data you provide to our service providers, and contractors that we use to support our business and operations (e.g., delivery services, financial institutions, fulfillment services, technical support, advertising, public relations, media and marketing services, legal services, call-in centers, e-commerce and other web-related services such as web hosting and web monitoring services, and event-related services such as online and offline data capture services) who have agreed to keep the information confidential and use it only to provide the applicable service(s). In some cases, we work with other companies who help to gather information from you or help us to communicate with you, such as SalesForce.com.

We may also disclose personal data to third parties (including without limitation, governmental agencies) if required to do so by law, regulation, or court order; to respond to governmental and/or law enforcement requests; to identify, contact, or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any claim, defense, or declaration in a case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may disclose personal data to third parties in connection with the sale, assignment, or other transfer of Coley, its business or the website to which such data applies. In the event that Coley goes through a business transition, such as a merger, acquisition by another company or sale of a portion of its assets, our customers’ personal information may be part of the assets transferred. Customers will be notified via prominent notice on our website prior to a change of ownership or control of their personal information. If, as a result of the business transaction, your personally identifiable information will be used in a manner materially different from that stated at the time of collection, you will be notified consistent with our Privacy Policy.

We may make full use of all information that is de-identified or otherwise not in personally identifiable form, including without limitation, user-generated content.

SECURITY

Coley takes appropriate steps to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, whether in transmission or storage. We recommend that you do not divulge your password to anyone. Coley will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Also, remember to sign out of your account and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Coley cannot ensure or warrant the security of any information you transmit to us or from our online products or services, and you do so at your own risk. Once we receive your transmission, we use our best efforts to ensure its security on our systems by using secure servers behind a firewall. Ultimately, you are solely responsible for maintaining the secrecy of your Coley password and account information. Please be careful and responsible whenever you are online. If you have any questions about security in our Services, you can contact us via the contact information below.

IT’S YOUR CHOICE: CONTACT PREFERENCES

We want to keep in touch with you in ways that you find to be beneficial. By submitting personal contact information, you are agreeing that we may communicate with you via email, telephone, direct mail, and/or other means of communication. If you don’t want us to use your contact information for promotional purposes (such as to tell you about other products and services that might be of interest), please tell us that when you provide your contact information. You can also let us know your preference later by contacting us as specified in the “Contact Us” section below, or by following the unsubscribe instructions in various communications that we may send you. Keep in mind that these preferences regarding promotional contacts do not mean that we might not contact you for other reasons, such as those related to an order you placed, an inquiry you made, a newsletter to which you may have subscribed, a membership you undertook, an event for which you registered, a legally required notice, and so on.

COPPA REQUIREMENTS

Our Services are not directed to children and we do not knowingly collect any personally identifiable information from children under 13 years of age through our sites.

CONTACT US

If you have questions or concerns related to this Privacy Policy or Coley information practices, would like to update or correct information you have provided, or would like to opt out of future communications, please contact us as follows:

Coley & Associates, Inc
140 Heimer Ste.400
San Antonio, TX 78232

Or email info@coleygts.com

CHANGES TO THIS PRIVACY POLICY

If this Privacy Policy changes, the revised policy will include a new effective date and will be posted on this website. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. Be sure to check the Privacy Policy whenever you submit personal data. The effective date of this Privacy Policy is the date first set forth above. Your continued use of the Services following the posting of any amendment will constitute your acceptance of that amendment.