Privacy Policy

Effective as of: April 2, 2021

Thank you for visiting https://castellanbc.com/ (the “Site”). The Site is a website owned, maintained, and operated by Castellan Solutions, Inc. (“Castellan Solutions”). Castellan Solutions respects, and is strongly committed to protecting, the privacy and security of both visitors and subscribers to the Site. The purpose of this Privacy Policy is to inform you about the information we collect and how and why we use that information.

Castellan Solutions owns all intellectual property rights, title, and interest in the Site and the “Castellan” mark and logo. By accessing or using the Site, you agree to comply with and be bound by the terms and conditions of our “Terms of Use”.

Castellan Solutions is committed to maintaining your confidence and trust.

Personal Information Collection.

The following details how Castellan Solutions collects personal information from visitors to the Site.

Cookies.

Castellan Solutions may deposit cookies on a visitor’s or a subscriber’s hard drive. A cookie is a piece of data stored on the user’s hard drive containing information about the user. Users who reject the cookie may still access and use the Site, but they may be limited in some areas of the Site.
Cookies can also enable us to track and target the interests of our visitors and subscribers to enhance their experience. Some of the information about how our users experience our Site, such as page views and specific pages visited, is logged by a third party company on our behalf, using cookies. We use various analytics tools which use cookies to identify the frequency of use of certain areas of our website and to identify preferences. For Google Analytics, you can find more information regarding how Google collects, uses, and shares your information at: http://www.google.com/policies/privacy/partners/. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.

General Log Information.

We automatically collect and store the following information about your visit to the Site:

• Your internet domain and Internet Protocol (IP) address; the browser used to access our Site; the date and time you access our Site; and the pages on our Site that you visit. We use IP addresses to analyze trends, administer the Site, track users’ movement, and gather broad demographic information for aggregate use.
• Referral and statistical information where we have links or advertisements to or from the Site. Such data may include aggregate data such as the number of clicks that occurred. It may also include specific data, such as whether you are a repeat visitor; whether you viewed or clicked on an advertisement and used our Site; and the identity of the website which you linked to or from our Site.
• When you visit or use the Site, we may employ tracking pixels which are used to track the online usage patterns of our visitors.

We collect referral statistics from links to let us know which links are useful, both to and from the Site. Likewise, we collect data from advertisements to let us know which ads are effective. This allows us to determine which ads may be of most interest and to help us control how many times a specific ad is displayed.

A visitor to the Site may elect to subscribe to receive our promotional information and notifications as well as other electronic communications or to participate in promotional events we offer. Castellan Solutions may ask a subscriber for personal information such as name, email address, title, employer, and phone number.

Personal Information Use.

We use Cookie and Log data to help us make our Site more useful to visitors, to learn about how the sections of our Site are being used, what information is of most or least interest, and how we may enhance ease of use by ensuring the Site can interface with the types of technology used by our visitors. We also use such statistics to tell us of any possible problems with the performance of the Site.

We use the personal data you voluntarily provide to us to respond to your inquiries, to deliver to the subscriber surveys or promotional information for which the subscriber may have expressed an interest.

We may use the personal information we collect in order to perform our contractual obligations, provide updates and other important information related to your activity on and with the Site, inform you of new services or changes in the Site and our services, to fulfill legal obligations we have to governmental authorities or other third parties, and for other legitimate business purposes.

The following describes additional ways Castellan Solutions uses personal information it collects from subscribers.

User Surveys.

From time to time, Castellan Solutions may ask our subscribers to complete user surveys. The survey may require disclosure by the subscriber of personal information such as name, email, and country of residence. Participation in these surveys is voluntary and a subscriber has a choice of whether or not to disclose this information to us. Castellan Solutions may use survey information for its own internal purposes to monitor or improve the usability of the Site.

Promotional Information.

Periodically, Castellan Solutions also may deliver to our subscribers promotional offers that we believe may be of interest to the subscriber. Participation in a promotional offer may require disclosure by the subscriber of personal information such as name email, and country of residence. Participation in these promotional events is voluntary and a subscriber has a choice of whether or not to disclose this information to us.

Personal Information Sharing.

Castellan Solutions is a provider of services headquartered in the United States, and as such may need to share information with internal personnel and our affiliates located in different geographic locations in order to perform our services. We may also share your personal data to third parties (within or outside your country of residence) who perform services on our behalf, including without limitation our technology providers and professional advisors.

We may disclose information (within or outside your country of residence) if we have a good faith belief that disclosure is necessary by law or the legal process, to protect and defend our or others’ interests or property, or to enforce agreements you enter into with us.

Notwithstanding the generality of the foregoing, Castellan Solutions may disclose personal information about visitors and subscribers to the Site to authorized law enforcement agencies or pursuant to a validly issued court order and such disclosure will be deemed an acceptable use of such information under this privacy policy.
Your information may be transferred to another company (within or outside your country of residence) in connection with a merger or in the event that our business is acquired in whole or part by another company.

We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes.

Castellan Solutions may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Site, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.

Unsubscribe/Opt Out.

Subscribers who no longer wish to receive our promotional information or other communications from us may unsubscribe using the tools provided in every email message we send or by contacting us at: info@castellanbc.com.

Grounds for Using Your Personal Data.

We rely on the following legal grounds to process your personal information:

Consent. Some uses of your personal data as described in this Privacy Policy are subject to your consent, such as marketing email communications.

Performance of a contract. We may need to collect and/or use your personal information as required for use to perform our contractual obligations. 

Legitimate Interests. We may use your personal information for our legitimate interests to provide our Site and services and to improve our Site and services and the content contained thereon. We may use technical information as described in this Privacy Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.

Accessing and Updating Personal Information.

• General. This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, please contact the program that provided you the product or service you requested or contact us at dataprivacyoffice@castellanbc.com. If your personal information changes or if you no longer desire our service, you have the ability to correct, update, or remove your personal information through the subscription management page on the Site.
  Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
  
• Your European Privacy Rights and Choices. If you reside or otherwise located in the territory of Europe, your privacy rights under the European data protection law include:
  • Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.
  • Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations.
  • Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
  • Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.
  • Right to data portability. You have the right to data portability of your own personal data by contacting us.
  • Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.
  • Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
    
• California Disclosures.
  California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to dataprivacyoffice@castellanbc.com with “California Shine The Light Rights” in the subject line.
  California Do Not Track Disclosure: At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, our Site is unable to respond to Do Not Track Signals.
  California Consumer Privacy Act Disclosures. Under the California Consumer Privacy Act, California residents have the right to request:
  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • The business or commercial purpose of collecting or selling personal information;
  • The categories of third parties with whom we share or sell personal information;
  • The categories of personal information about you that we have sold; and
  • The specific pieces of personal information we have collected about you.
    
    Additionally, you have the right to request deletion of your personal information, the right to opt out of the sale of your information (if applicable) and the right not to be discriminated against for exercising any of your CCPA rights.
    In the twelve (12) months preceding the Effective Date of this Privacy Policy, Castellan Solutions may have collected or received, from our customers and from third parties in connection with providing our Site and services, information about California consumers in each of the following categories (as defined in the CCPA) and disclosed the information to our service providers for business purposes:
• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or account name.
• Any categories of personal information described in subdivision (e) of Section 1798.80.
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
• Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  
  Castellan Solutions does not sell personal information for monetary consideration under CCPA. Personal data may be provided to our services providers and to third parties under Section 1798.140(t)(2)(A) of the CCPA. In the event that the use of third party cookies constitutes a “sale” under CCPA, you may opt out of the use of such cookies as described above in this Privacy Policy.
  
  Our contact information is listed at the bottom of this policy. We will ask for your name, email address and company name. If your name, email address and company name are insufficient to verify your identity and assess your privacy request, we may need to ask for additional information. You may also designate an authorized agent to make a CCPA privacy request.
  
  Castellan Solutions will do its best to honor GDPR and CCPA deletion requests. The right to request deletion is not absolute under CCPA or GDPR; Castellan reserves the right to determine each request on a case-by-case basis and retain (and/or not de-identify, as applicable) all or some of such information if it is required or permitted to do so in compliance with CCPA Section 1798.145(a) or GDPR Article 17(3). For example, Castellan is required to retain transactional information for purposes of taxation, accounting, and defense/exercise of legal claims.

Security and Retention.

For website security purposes and to ensure that our service remains available to all users, Castellan Solutions employs commercially available software programs to monitor network traffic to identify unauthorized attempts to change information, or otherwise cause damage. In those instances where we transmit your personal information between your browser and our server, we will encrypt the information using industry standard protocols such as Transport Layer Security (TLS) or Secure Socket Layer (SSL). The URL in your browser will change to “HTTPS” instead of “HTTP” when this security feature is in use. Your browser may also display a lock symbol on its bottom task bar line to indicate secure transmission.

Castellan Solutions also has implemented commercially reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or access your personal information for improper purposes. Thus, you acknowledge that you provide your personal information at your own risk.

Except for authorized law enforcement investigations, no other attempts are made to identify individual users or their usage habits other than those uses identified in this privacy policy. Castellan Solutions will investigate intentional misuse of secure information on its Site and may refer such investigation to law enforcement agencies.
We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. Notwithstanding the generality of the foregoing, we store email addresses until the user requests to be unsubscribed or removes themselves through any self-service tools offered to the user.

Users Outside the United States.

The Site is controlled and operated from the United States. If you are an individual from the European Union, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may process or store the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities. Personal data may also be transferred from the country of your residence to other countries, including the United States.

Privacy Policy Changes

We reserve the right to revise or modify this privacy policy at any time and in our sole discretion. We will post a notice at the top of the first page of this Privacy Policy showing the date when it was last updated.

We will use information in accordance with the privacy policy under which the information was collected. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users in accordance with the notification procedures set forth in this statement. Users will have a choice as to whether or not we use their information in this new manner.

Privacy of Minors

If you are under 18 years of age, then please do not use or access the Site at any time or in any manner. Castellan Solutions does not knowingly collect or maintain personal information through the Site from persons under 18 years of age, and no part of our Site is directed to persons under 18. If Castellan Solutions learns that personally identifiable information of persons less than 18 years of age has been collected through the Site, then Castellan Solutions will take the appropriate steps to delete this information.

Notification Procedures

Castellan Solutions will deliver notice, whether such notifications are required by law or are for marketing or other business related purposes, to our Site visitors and subscribers via email notice, or by written or hard copy notice, or through conspicuous posting of such notice on our Site, as determined by Castellan Solutions in its sole discretion. Notwithstanding the foregoing, Castellan Solutions reserves the right to determine the form and means of providing notifications to our Site visitors or subscribers.

Inquiries

Should you have any questions or concerns about this Privacy Policy or need to update certain personal information, please contact us:

• USA: (800) 478-7645
• International: +1 610-878-2644
• E-mail: dataprivacyoffice@castellanbc.com 
• Mail:
  Castellan Solutions, Inc.
  Attn: Privacy Officer
  800 Adams Avenue, Suite 300
  Audubon, Pennsylvania 19403

EU Customers

Our legal entity in the EU is Castellan Solutions Limited. If you are a resident in the EU and want to contact us with regard to your data protection rights in the EU or exercise any of those rights, you can do so by emailing us at dataprivacyoffice@castellanbc.com

We will investigate and respond to your inquiry. Your inquiry will be treated confidentially, and will not be shared with external parties, except Castellan Solutions service providers.

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