Last updated: January 19, 2021
The privacy of personal information Carver Edison collects from you in connection with your use of the Sites is important to Carver Edison. Carver Edison may have made to its corporate clients certain specific representations and warranties with respect to the privacy and security of such information (“Privacy and Security Agreements”) and Carver Edison will abide by the terms of such Privacy and Security Agreement.
How and why we obtain personal information
We may use personal information about you to service, maintain, and protect your elections concerning your employer’s employee stock purchase plan or other equity plan for which we are providing services (“Services”); respond to inquiries from you or your representative; develop, offer, and deliver products and services; for reporting and analytical purposes, security purposes, or to fulfill legal and regulatory requirements. We may collect public and non-public personal information about you from any of the following sources
How we protect information about you
We consider the protection of personal information to be a foundation of customer trust and a sound business practice. We employ reasonable physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology. We restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.
How we share information about you with third parties
We share the personal information we receive from you with unaffiliated third parties solely to the extent required in connection with our performance of the Services to your employer or as your employer may instruct. Unaffiliated third parties includes service providers performing services on our behalf and third parties that provide products and services to you through your relationship with us. We do not share your personal information with unaffiliated third parties for use in marketing their products and services. We also may share personal information with governmental agencies, other regulatory bodies and law enforcement officials, and to respond to a subpoena. We may also transfer or assign information, including your personal information, in connection with a merger, acquisition, reorganization, liquidation, change in control or other sale by or of us or any affiliated entity (in each case whether in whole or in part).
Information We Collect Automatically
When you use our digital offerings, we may collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving our website design and functionality, and personalizing your experience. We may use cookies and similar data collection technologies to gather this information.
Cookies and similar technologies
We and our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. Our cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.
You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie, or if you delete cookies from your device, you may experience some inconvenience in your use of our digital offerings. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.
Protecting children’s privacy online
Our digital offerings are not directed to individuals under the age of thirteen (13). We do not intentionally collect information through our digital offerings from those we know are under 13, and we request that these individuals do not provide personal information through the Sites.
Our digital offerings do not currently take any action when they receive a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.
Carver Edison, Inc. is the controller of the personal information we collect through our digital offerings and our Cashless Participation™ service. We process personal information for the purposes described in the section entitled, “How and why we obtain personal information,” above. We process personal information to further our legitimate interest in providing our digital offerings, products and services to you and other users. If required, we may also process your personal information as necessary to comply with legal obligations to which we are subject. We may share your personal information with the categories of recipients described in the section entitled, “How we share information about you with third parties,” above.
Unless legally required to retain information longer, we will retain your personal information for as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
Your personal information may be transferred, stored and used in the United States of America (USA). The USA may have data protection laws that are different to the laws of your country. We are committed to adopt all the necessary measures and safeguards as to the cross-border data flow, as set forth by applicable laws. When required by applicable laws, we will transfer data subject to the use of appropriate safeguards.
To the extent provided by applicable law, you may have the right to: (a) confirm whether we process personal information about you; (b) access certain personal information we maintain about you; (c) exercise your right to data portability; (d) request that we update, correct or rectify, amend, erase, or restrict your personal data; (e) withdraw any consent to processing you have previously given, if any; and/or (f) object at any time to the processing of your personal information on legitimate grounds relating to your particular situation. You have a right to file a complaint with a supervisory authority.
To exercise the above rights, please contact us using the information in the section entitled, “Questions?,” below. We will consider and process your request in a manner consistent with applicable legislation requirements.
Additional Information for California Residents
Please view our Additional Information for California Residents and Privacy Policy Supplement - CCPA below. This additional information is provided for purposes related to the California Consumer Privacy Act of 2018, as amended (the “CCPA”) and applies to the personal information and Carver Edison companies that are subject to CCPA.
This Additional Information for California Residents and Privacy Policy Supplement – CCPA (“Supplement”) supplements our main Privacy Policy above our “Main Privacy Policy”.
This Supplement is provided for purposes related to the California Consumer Privacy Act of 2018 (“CCPA”), and applies to the personal information and Carver Edison companies that are subject to the CCPA. As used in this Supplement, “personal information” means information that is considered to be personal information as set forth in the CCPA and is not otherwise excluded from the scope of the CCPA.
Additionally, for California residents, the CCPA imposes certain obligations on businesses and allows a resident to make certain requests (“CCPA requests”) to a business regarding the personal information that the business maintains.
It is important to note, however, that the CCPA does not apply to all businesses, nor does it apply to personal information maintained by companies that are covered under certain exemptions described in the CCPA.
For example:
In general, if you are a customer of ours or you otherwise interact with us, we collect various types of personal information about you. The amount and types of personal information we collect will vary depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you. The categories of personal information that we may collect about you are:
Please see the section titled “How and why we obtain personal information” in our Main Privacy Policy for a description of some of the categories of sources from which we collect personal information. In addition to the sources described in that section, depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we may obtain personal information from the following sources:
Please see the section titled “How and why we obtain personal information” in our Main Privacy Policy for a description of some of the business or commercial purposes for which we collect personal information. In addition to the purposes described in that section, below are additional business or commercial purposes for which we collect personal information:
Please see the section titled “How we share information about you with third parties” in our Main Privacy Policy for a description of some of the categories of third parties with which we may share personal information. In addition to the categories described in that section, depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we may share personal information with third parties that provide products or services to you through your relationship with us. We do not share personal information about you with unaffiliated third parties for their use in marketing their products and services. In addition, we do not sell personal information about you and have not done so at any time during the 12-month period preceding the date of this Supplement. As required by the CCPA, we disclose that we do not have actual knowledge that we sell personal information of minors under 16 years of age.
Like most businesses, we disclose personal information to third parties for our business purposes. Depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we disclose (and during the 12-month period preceding the date of this Supplement, we have disclosed) for business purposes the personal information that is encompassed by one or more of the categories described above in the section entitled “Categories of personal information we may collect about you.”
The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents generally have under the CCPA. Please note that the CCPA contains a number of exemptions and exclusions, so some or all of these rights may not apply to you with regard to personal information collected by us. Please see “Carver Edison Companies and the CCPA” below for more information. As used below, a “consumer” means a resident of the State of California and a “covered business” means a business that is subject to the CCPA.
A consumer has the right to request that a covered business that collects a consumer’s personal information disclose to that consumer the categories and specific pieces of information the business has collected. A consumer also has the right to request that a covered business that collects a consumer’s personal information disclose to that consumer the following:
A consumer has the right to request that a covered business delete any personal information about the consumer that the business has collected from the consumer. However, the covered business is not required to comply with such a request if the covered business needs to maintain the consumer’s personal information for certain purposes set forth in the CCPA.
A consumer has the right to request that a covered business that sells the consumer’s personal information, or that discloses it for a business purpose, disclose to that consumer:
A consumer has the right to direct that a covered business that sells personal information about the consumer to third parties not sell the consumer’s personal information.
A covered business cannot discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.
As described in this section, the requests that a consumer can make to a covered business are referred to as “CCPA requests.”
CCPA Exemptions: Please note that certain types of personal information collected or maintained by a covered business are exempt from the CCPA. For example, a covered business has limited obligations, or in some cases no obligations, under the CCPA with regard to the following types of personal information:
Furthermore, under the CCPA, there are a number of situations where a covered business may refuse to honor a CCPA request to delete a consumer’s personal information and is allowed to continue to maintain the consumer’s personal information. Some examples include situations where retention of the personal information is necessary to:
Please note that the description of the CCPA set forth in this Supplement is a summary of only certain aspects of the CCPA and is not, and should not be considered to be, a complete description of the CCPA. In addition to what is described above, the CCPA includes other exemptions that apply to particular types of personal information and particular businesses, as well as additional situations where a covered business is not required to honor a consumer’s request to delete the consumer’s personal information.
Also, because we do not sell personal information, Carver Edison companies do not have any obligation under the CCPA to accept CCPA requests requesting that the Carver Edison company not sell a consumer’s personal information.
If you wish to submit a CCPA request to a Carver Edison company, you may initiate your request through one of the options below. Before submitting your request, please ensure you have reviewed the CCPA Exemptions above as well as the cases detailed above where the applicable Carver Edison company may have no obligation under the CCPA to accept any requests.
Your CCPA request may be subject to additional verification, including but not limited to (a) confirming that you are a California resident and (b) confirming your identity or the identities of those authorized to submit requests on your behalf.
In general, you should expect to receive a response within 45 days of the date we receive your request.
Under the law, you are limited to two requests during any 12- month period.
Your CCPA request will be processed by, and limited in scope to, the Carver Edison company to which the request was submitted. If you have or had a relationship with more than one Carver Edison company and you desire to submit a request to all Carver Edison companies with which you have or had a relationship, you will need to make a separate CCPA request to each Carver Edison company.
If you wish to submit a CCPA request to us, please contact us at legal@carveredison.com. If you have any questions or concerns about a Carver Edison company’s privacy policy and practices, please contact us at legal@carveredison.com.
