Last Updated August 22, 2024

CRETE UNITED PRIVACY NOTICE

Crete United takes your privacy seriously. In this Privacy Notice, we may refer to ourselves as “we”, “us” or “our”, by which we mean Crete United and its subsidiaries. We use the word “you” throughout this Notice to refer to anyone within the scope of this Privacy Notice. This Notice discusses:

• Scope
• Information Collection
• How We Use Your Personal Information
• How We Disclose Your Personal Information
• Cookies and Automatic Data Collection
• Links to Affiliate Sites
• Links to Third Party Sites
• Sales and Sharing of Personal Information and Use of Personal Information for Targeted Advertising
• Opt-Out of Correspondence
• Information Retention and Security
• Your Rights and Choices
• Exercising Your Rights
• Children’s Privacy
• Changes to this Notice
• Contact Us

Scope

This Privacy Notice describes how we collect, use, protect, and process Personal Information we collect from or about you when you visit websites or use mobile apps operated and controlled by Crete United, communicate with us, or otherwise interact with us in your capacity as a consumer. This Privacy Notice does not apply to employees or job applicants of Crete United, or our subsidiaries. Unless specified otherwise, this Privacy Notice also does not apply to our Partner companies, which generally have their own privacy notice on their websites that describes how they collect, use, and disclose information. Throughout this Notice, we use the term “Services” to describe our product and services offerings, including our websites, mobile apps, products, solutions, and any other products or services offered by Crete United or its Partner companies.

This Privacy Notice explains how Crete United may use and disclose information we collect from and about you, as well as your ability to control certain uses of it. By visiting our website, interacting with us, or providing us with your data, you consent to the collection, use, and disclosure of your Personal Information in accordance with the terms of this Privacy Notice. Please review this Privacy Notice carefully to understand these terms and your rights and options.

If your organization has a separate contract or agreement regarding Crete United’s use and processing of Personal Information, to the extent that agreement conflicts with this Privacy Notice, the agreement will apply. However, where this Privacy Notice provides additional rights to individuals beyond the rights included in any such agreement, we will also afford individuals with the rights and choices they may have under this Notice.

Information Collection

The term “ Personal Information” in this Privacy Notice means any information which could identify you as an individual, either directly (for example, your name) or indirectly (such as an IP address or other unique identifier), or any information that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Crete United collects personal information from you directly (such as when you provide it to us, or fill out a form on our website), automatically, and from third parties or other sources.

Crete United has collected and processed the following categories and types of Personal Information from individuals in the last 12 months:

• Identifiers, such as your name, contact information, address, telephone number, online identifiers, and demographic information such as date of birth and gender.
• Commercial information, such as records of products or services purchased, billing details, and information about previous transactions.
• Internet or other similar network activity, such as information about your interactions with our Services or advertisements.
• Geolocation data, such as the physical location of you or your device that accesses our Services.
• Audio, electronic and visual information, including photographs, videos, if you provide a testimonial or voice recordings, if you interact with our customer service or provide a testimonial.
• Inferences we derive from the information we collect to create profiles reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Information categories listed in state statutes, including information listed under California Civil Code Section 1798.80, subdivision (e), such as name and contact information.
• Social media profile information, when you share it with us or use it to contact us.
• Account-related information, such as information related to any account you create or set up with Crete United.
• Device information and unique device identifiers, such as your IP address, operating system, or the serial number of your device.
• Preference information, including your communication, language and time zone preferences.
• Any other Personal Data you choose to provide to us.
• Any other Personal Data you consent to the collection of at the time of collection.

We may not collect each of the above categories of personal information from every individual who interacts with us, or who uses our Services.

How We Use Your Personal Information

We process your Personal Information with your consent, to perform our contractual obligations, to provide you with services you request from us, where it is in our legitimate interest to process such information, and where we have a legal obligation. More specifically, we process your information for the following purposes, including to:

• Provide you with our Services.
• Manage your account.
• Contact you for marketing purposes and opportunities.
• Communicate with you about products or services you request from us, including product and service support related to products and services you purchase, and to provide you with customer support when you otherwise contact us.
• Invite you to participate in surveys, or to provide feedback to us about your experience in working with us.
• Operate, improve, and enhance our business, products, and service offerings.
• Perform our contractual obligations with other entities, organizations, and third parties.
• Identify trends in the use of our products and services.
• Personalize your experience when you interact with us, including on our website.
• Understand the effectiveness of our marketing campaigns and to tailor our communications to you.
• In connection with our cybersecurity efforts.
• Ensure continuity of service to you if we sell, assign, or transfer part of our business or enter into a relationship with a successor or partner entity.
• Defend Crete United against actual or threatened litigation.
• Comply with subpoenas, regulatory inquiries and other lawful judicial process, and to comply with our legal and regulatory obligations.
• 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 our website, products, and services.
• Any other purpose you consent to, or instruct us to.

We may aggregate and de-identify the Personal Information in our database and create reports that do not personally identify any individuals.

We may also combine Personal Information we receive from or about you from one source, with Personal Information we receive from or about you from other sources, or across interactions with you. We may use this information to build a profile about you and your habits, including to be able to tailor our marketing content to you.

How We Disclose Your Personal Information

Crete United discloses Personal Information we collect for a business purpose to the following categories of third parties and for the following purposes:

• Service providers, consultants, and vendors, to perform functions on our behalf such as website hosting, marketing automation, analytics, site optimization, payment processing, and other services that we contract for.
• Corporate affiliates and parent companies, to provide and maintain our Services, to benchmark our products and services against our corporate goals, and for financial and administrative purposes.
• Successor entities. If we sell all or part of our business, make a sale or transfer of assets, or are otherwise involved in a merger, restructuring or business transfer, including as part of the due diligence and transaction process;
• Court orders, law enforcement requests, and legal process Under applicable law, including laws outside your country of residence to comply with subpoenas and other legal processes;
• As otherwise necessary to pursue available remedies or limit damages we may sustain; protect our operations; protect the rights, privacy, safety or property of us, you and others; and to enforce our website Terms of Use or other of our terms and conditions.
• As you otherwise direct us to or consent to.

Cookies and Automatic Data Collection

As with most websites, our website may automatically collect certain information about you through cookies, clear GIFs, pixel tags, session replay technology, and other similar technologies. We refer to these automatic data collection technologies throughout this Notice as “cookies.” Our website uses both third party and first party cookies. We use cookies to collect Personal Information from you, including:

• Browser and device identifiers, such as IP address, device type, computer and connection information such as your browser type, and operating system and version.
• Usage data, such as confirmation when you open an email that we send you; and the URLs which lead you to and around our website including the date and time of access.

We may combine device identifiers and usage data with other personal information we collect from or about you to create a profile about you and your interactions with us.

We rely on partners to provide many features on our website using data collected through cookies and similar tracking technologies. We use cookies and similar tracking technologies for the following purposes:

• Website Operations: Enabling features that are necessary for providing you the services on our website, such as tracking content views, providing website security features, improving website functionality, and remembering your preferences to continually improve it and better serve the needs of our users.
• Analytics: Allowing us to understand how our services are being used, track site performance, and make improvements. Our website uses Google Analytics to track and monitor use of our website. Google Analytics shares this data with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• Social Media: Enabling the sharing of content from our services through social networking and other sites.
• Marketing: Allowing us to tailor content, advertisements, and communications to you based on your interactions with us.

The cookies used on our website may allow us, or other third parties, to identify you across other media, websites, or apps, or through your use of our other products or Services to help tailor our offerings and provide enhanced personalization and communications.

Cookie Preferences and Choices

We appreciate that you may wish to express certain preferences with respect to some or all categories of cookies used to collect information, including Personal Information, from you, through our websites and applications. You may express your preferences regarding our collection of information via cookies through:

• Browser settings. Most web browsers automatically accept cookies. You can change your browser settings to notify you of the cookies being set or updated, and to block cookies. Please note that if you have turned off all cookies, some features of our website may not be available to you or otherwise function as intended. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.
• Expressing preferences to third parties. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.
• Cookie consent tool. Our website uses a cookie consent tool to inform you of our use of cookies on our website, and to provide you with choices regarding the categories of cookies we use to collect information from you.

Links to Third Party Sites

Our website contains links to websites run and controlled by third parties (“Third Party Sites”). These links are provided to users as a convenience and services to our users. We do not control the means by which your Personal Information is collected through Third Party Sites or the software used to collect it, nor do we control the security implemented by the third party that controls any Third Party Sites. When you visit any Third Party Site, including through links accessible on our website, this Privacy Notice will cease to apply, and instead, the privacy policy and practices of the Third Party Site will apply to the Personal Information collected through that Third Party Site. We encourage you to review the privacy policies listed on every Third Party Site that you visit.

Sales and Sharing of Personal Information, and Use of Personal Information for Targeted Advertising

Crete United does not sell personal data for money, but in the last 12 months, we have shared personal data including identifiers, commercial information, internet or similar network activity, inferences, and geolocation data with providers of advertising and analytics services, network advertisers, and partners who assist us with target audience creation. This sharing and disclosure is considered a “sale” or “sharing” of personal information for the purpose of targeted advertising under some state laws.

If you are a resident of certain jurisdictions, you have the right to opt-out of the sale of your Personal Information to third parties, and to limit our use and disclosure of your information for targeted advertising. Please review the “Your Rights and Choices” section below for more information.

Opt-Out of Correspondence

You may choose to limit or cease receiving marketing correspondence from us by using the opt-out option in emails you receive from us, or by emailing or calling us at the email and/or phone numbers listed below in the “Contact Us” section. Please allow us up to ten business days to process your request to opt-out or unsubscribe.

Information Retention and Security

We retain your Personal Information for the period necessary to fulfill the purpose(s) for which it was collected as outlined in this Privacy Notice, unless a longer retention period is required by law or is needed in order to fulfill a legal requirement to which Crete United is subject.

We utilize reasonable physical, technical, and organizational measures and procedures to safeguard and secure Personal Information from unauthorized use, unauthorized disclosure, and loss. However, you should be aware that no data storage or method of transmission can be guaranteed to be 100% secure or error free, and we cannot guarantee the security of your Personal Information.

Your Rights and Choices

Depending on the jurisdiction in which you reside, you may have additional rights and choices regarding your Personal Information, including the rights listed below. While we use the term Personal Information throughout this Privacy Notice, we intend for this to include “personal data” where that is the term used under applicable law. If you have questions about whether you live in a jurisdiction that affords privacy rights, please contact us using one of the methods listed below.

Right to Request Access or Right to Know

You have the right to request that we disclose information to you about our collection and use of your Personal Information over the past 12 months. You have the right to request the following:

• The categories of Personal Information we collected about you.
• The specific pieces of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• The business or commercial purpose for collecting your Personal Information.
• The categories of third parties with whom we have disclosed your Personal Information in the preceding 12 months.
• The categories of Personal Information we sold or shared about you, and the categories of third parties to whom the Personal Information was sold or shared by category of Personal Information.

Once we receive and confirm your verifiable consumer request, we will provide you with the information you request unless an applicable exception applies.

Right to Portability

After you make a request to access or know your Personal Information, you have the right to request to obtain a copy of this information in a portable, readily usable format that allows you to transmit the information to another party, to the extent it is technically feasible. You may also have the right to request that we transfer your information to another organization, under certain circumstances.

Right to Deletion or Right to Erasure

You have the right to request that we delete any of the Personal Information that we collect or retain about you, subject to certain exceptions. After we receive and verify your request, we will delete (and direct any of our service providers that hold your Personal Information on our behalf to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining your Personal Information is necessary for us or our service providers, as permitted by law.

Right to Opt-Out of the Sale or Sharing of Personal Information, or the Use of Personal Information for Targeted Advertising

You have the right to opt-out of the sale or sharing of your Personal Information. In some states, this right is known as the right to opt-out of the use of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of certain decisions.

As indicated above in the section titled “Sales and Sharing of Personal Information, and Use of Personal information for Targeted Advertising,” in the last twelve months, we have not “sold” or “shared” Personal Information. If you still wish to express your preferences to us to not sell or share your Personal Information, you may exercise your right to opt-out by following the instructions set forth in this section of this Privacy Notice titled “Exercising Your Rights.”

Right to Limit Certain Uses and Disclosures of your “Sensitive Personal Information”

You have the right to limit our use and disclosure of your “Sensitive Personal Information,” as that term is defined in applicable statutes, where we have collected it to use as necessary to perform the services or provide the goods reasonably expected by you, and as otherwise authorized by the statute and regulations. We do not collect Sensitive Personal Information from consumers of our Services. If this changes, we will only use your Sensitive Personal Information in ways that you would reasonably expect are necessary to perform the services or to provide you with the Services you request.

Right to Correct Personal Information if the Information is Inaccurate

If you believe or discover that Personal Information we have collected about you is inaccurate, you may contact us to request that we correct and update the information so that it is accurate.

Right to Restrict or Object to Processing

You may have the right to restrict certain processing of your Personal Information, or to object to certain processing of your Personal Information, including where our legal basis for the processing is your consent, where the processing involves Sensitive Personal Information, or where it involves automated decision-making technologies. This right is subject to certain restrictions.

Right to Appeal

If you are a resident of certain jurisdictions, you have the right to file an appeal with us if we deny your request to exercise your rights. Requests to appeal can be communicated through the same means by which your request was submitted. If we deny your appeal, you may have the right to appeal to your state regulator. We will provide you the information of the applicable regulator if we deny your appeal.

In addition to the above rights, you also have the right to:

• Appoint an individual to exercise your rights on your behalf, or to exercise rights on behalf of your minor child, if we have collected their information.
• Access information about automated decision making (as applicable).
• Opt-out of automated decision making (as applicable).
• To not be discriminated against for exercising your rights.

Exercising your Rights

If you believe you reside in a jurisdiction that affords the consumer privacy rights listed in this policy to its residents and you wish to exercise any of the rights described above, please submit a request to us by one of the following methods:

• Calling our customer service team, toll free, at 833-273-8364
• Emailing us at privacy@creteunited.com
• Writing to us at:
  ATTN: Privacy Manager
  3700 South Boulevard
  Suite 250
  Charlotte, NC 28209

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will take steps to verify your consumer request, including that you are the person making the request, or you have authority to make the request on behalf of the individual the request relates to. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format: We endeavor to respond to verifiable consumer requests within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination: We will not discriminate against you for exercising any rights you have under applicable law. Unless permitted by applicable law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by state law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Children’s Privacy

Our website is provided for and targeted to adults and is not intended to be used by children under 18 years of age. We do not knowingly collect Personal Information from children and individuals under the age of 18. If you believe we have been provided Personal Information from or about a child under 18, please contact us at the email below. If we have stored any such Personal Information in our database, we will delete it as soon as reasonably practicable after receiving notice from you.

Changes to this Notice

This Privacy Notice is subject to change. If we make any material changes, we will notify you by means of a notice placed on our website prior to the change becoming effective and we will update the date above accordingly. We encourage you to periodically review this Privacy Notice. By using our website and Services, you agree to the terms and conditions in the most updated Privacy Notice.

How to Contact Us

If you have any questions or concerns regarding the Privacy Notice related to our website, please feel free to contact us at the following email, telephone number or mailing address:

Email: privacy@creteunited.com

Toll Free Phone Number: 833-273-8364

Mailing Address:

ATTN: Privacy Manager
3700 South Boulevard
Suite 250
Charlotte, NC 28209