Privacy Policy
Central Desktop Acquisitions, Inc. and its subsidiaries (collectively, “CD”, ‘we’ or ‘us’) recognize and respect the importance of protecting your privacy. To that end, we have adopted the principles set forth in this privacy policy (the “Policy”) to govern our use and disclosure of your personal information. The following Policy describes how we collect and use your personal information and describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your rights” section. We recommend that you carefully review this Policy before providing us with your personal information. Scope
This Policy consists of the following sections:
Section 1. Users of our website : this section applies if you use the CD website,
www.imeetcentral.com (the “Website”), and explains how we use personal information of the
users of the Website.
Section 2. Users of our business solutions : this section applies if: (i) you work for an
organization which uses our business solutions, (ii) if you use the mobile applications
(“Apps”) that interface with our business solutions or (iii) if you use our Website
subdomains accessible only after login to a customer account (“Product Pages”), and
explains how we use personal information in the course of providing our business
solutions.
Section 3. Your rights and our data protection practices : this section applies to the users
of our Website and the users of our business solutions and sets out further information
on CD’s data protection practices and your data protection rights.
This Policy does not apply to information processed: (a) by other CD websites that have their
own privacy policy; (b) by third party websites to which our Website may link, and (c) on behalf
of your employer in the context of our business solutions, where your employer has control over
such information as further explained under Section 2 below.
‘You’ or ‘your’, in this Policy, means you as a natural person, rather than any legal entity which is
our customer (such as your employer) which you may represent when you use our business
solutions.
Users of our Website
This section applies to you if you are a user of our Website and explains how we process your
personal information when you use our Website or submit queries through our Website. 1.1.Information we collect Internet or electronic network activity information as follows:
Usage data, such as performance metrics related to your use of the website;
Log data generated when you use the Website, including Internet Service Provider (“ISP”),
browser type, referring/exit pages, the files viewed on our site, referrer URL, key words
entered into a search engine, operating system, date/time stamp, and/or clickstream data
to analyze trends in the aggregate and administer the Website;
Device data, such as the configuration of your device.
Identifiers associated with cookies or other technologies that may uniquely identify your device
or browser, your Internet Protocol (“IP”) address and your approximate location.
Other identifiers, including your name, company name, title, telephone number, email address
and country.
Inferences, including your choices, behavior and preferences when you use the Website and
when you open or click on a link in our emails.
Commercial information about the services you purchased or considered.
1.2.Sources of Information
We may collect information from you from the following categories of sources:
Information you provide, such as other identifiers and commercial information you
provide when you communicate with us about or purchase our products and services or
when you complete forms on our Website.
Information collected automatically, such as internet and electronic network activity,
identifiers and inferences when you use our Website.
Information from third parties, such as internet and electronic network activity and
commercial information, including from our business partners, data enrichment service
providers, analytics and advertising vendors (as described in the ‘Use of Cookies and
Other Web Technologies’ section), and social networking sites (as described in the ‘Social
Networking and Public Forums’ section).
1.3.How and why we use personal information
We collect, process, use and store your personal information for the following business and commercial purposes in accordance with our legitimate business interests and legal requirements or with your consent where required:
to provide you with information in response to your requests;
to maintain the accuracy of the information we collect;
to help us develop new services, solutions or features that meet your needs;
to manage language preferences and connect you with your nearest account manager;
to maintain contact data about you or a third party (such as, your employer);
where necessary to protect or conduct our business and pursue our, or our affiliates’,
legitimate business interests, which include the security of our systems and our
operations and the exercise or defense of legal claims;
to comply with privacy laws and other regulations such as to manage consent
requirements;
to give you a customized interactive experience;
to measure interest in various CD solutions and services;
to inform you about new CD solutions and services or features and functionalities;
to inform you of products, services, marketing plan and other business related items from
CD which may be of interest to you;
1.4.Lawful bases for processing personal information (applies only in the European Economic Area)
CD processes personal information where one or more of the following conditions that are set
out in the General Data Protection Regulation (GDPR) apply:
Where it is necessary in order for us to conduct our business and pursue our, or our
affiliates,´ legitimate interests for internal administrative purposes. In particular, we
collect, use and store your personal data: (i) to communicate and manage our relationship
with our customers; (ii) to maintain contact data about you or a third party (such as, your
employer); (iii) to inform you of products, services, marketing plan and other business
related items from CD or third parties which may be of interest to you; (iv) to ensure the
security of our systems and our operations, and (v) where appropriate, to establish,
exercise or defend legal claims.
Where it is required by applicable privacy laws to obtain your consent: (i) CD will send
you direct marketing in relation to relevant products and services provided by CD; (ii) CD
places cookies and uses similar technologies in accordance with the ‘Use of Cookies and
other Web Technologies’ section of this Policy and the information provided to you when
those technologies are used;
Where it is necessary in order for us to comply with our legal obligations, such as
requirements to process requests by government or law enforcement authorities.
1.5.Use of Cookies and Other Web Technologies 1.5.1.Cookies
CD and our service providers use cookies or similar technologies to analyze trends, administer
the Website, track users’ movements around the Website, gather demographic information
about our user base as a whole, and understand the urgency and nature of the need of our
website visitors.
Cookies are pieces of information that a website transfers to your computer’s hard drive for
record-keeping purposes. Cookies can make a website more useful by storing information about
your preferences for a particular site. Most browsers are initially set to accept cookies. If you
prefer, you can set your browser or device settings to limit certain tracking or to refuse cookies
on our Website, but by doing so, you may not be able to use certain features of the Website or
take full advantage of all of our offerings. Please refer to your browser’s “Help” section or device’s
settings for more information on how to change these settings. Our system may not recognize
“Do Not Track” requests or headers from some browsers. You can manage your cookie
preferences in your internet browser.
Personal information in cookies is treated with the same level of protection as other personal
information you provide to us. The information generated by our service providers relating to
our website(s) is used to identify our visits and to determine your interests mainly for sales and
marketing purposes. To determine those interests, our service providers will track the visitors’
behavior on our website(s), and provide us with publicly available information about you such
as social media profiles and information. Such information will not be shared with third parties,
but may be stored on servers of other applications we use to serve you such as CRM systems.
1.5.2.Widgets
To the extent our Website may include widgets, which are interactive mini-programs that run on
our site, to provide specific services from another company (e.g. displaying the news, opinions,
music, etc.), personal information, such as your email address, may be collected through the
widget and shared with the company that created it. Those third parties may further process
and/or use your personal information in accordance with their privacy policies.
1.5.3.Mobile Analytics
We use mobile analytics software to allow us to better understand the functionality of our mobile
software on your phone. This software may record information such as how often you use the
application, the events that occur within the application, aggregated usage, performance data,
and where the application was downloaded from. To the extent we automatically link any
collected data to other information we collect about you, we do so for reasons such as to improve
CD services we offer you and to improve marketing, analytics, or the Website’s functionality.
1.5.4.Framing
To the extent we employ any framing techniques on our Website, please be aware that you are providing your personal information to CD and not to a third-party site.
1.6.Testimonials
To the extent CD posts customer testimonials/comments/reviews on any of our Website that
contain personal information, we obtain any required consent(s) prior to posting the testimonial.
1.7.Social Networking and Public Forums
To the extent CD offers certain publicly accessible blogs and/or community forums on our
Website, you should be aware that any information you provide in these areas may be broadly
available to others, and can be read, collected, and used by others who access them, potentially
inside or outside CD. When persons external to CD access the information you choose to submit
in such blogs or community forums, they will be responsible for how they use it and we do not
have control of such use of your information. Also, please note that individual blogs and/or
forums may have additional rules and conditions.
Collection and sharing of personal information on social media apps and websites is governed by
the privacy policies and practices of the social media providers. CD may collect information about
you in connection with social networking sites in several ways, including:
When you sign in to a CD app or website using a social networking account;
When you use a CD app on a social networking site or choose to join (or “like”) a CD page
on a social networking site. In these situations, the social networking site may make some
information about you available to CD;
When you interact with a CD social networking page or content, we may use cookies to
learn which links you clicked;
When you make information publicly available on your social networking page.
We use this information for purposes described in this Policy.
1.8.Chat
We may use a chat feature to help with any questions or concerns. If our chat feature is offline
we may still collect your name, email address and telephone number so that we may reply to
your request.
1.9.Children
We do not knowingly collect any personal information from children under 13 years old through
our Website. However, if the parent or guardian of a child under 13 believes that the child has
provided us with personal information, the parent or guardian of that child should contact us
using the Privacy Contact Information provided at the end of this policy if they want this information deleted from our files. If we obtain knowledge that we have personal information about a child under 13 in retrievable form in our files, we will delete that information from our existing files. We do not sell the personal information of minors aged 13 to 16.
1.10.Third Party Websites and Cookies
Our Websites may contain links to third-party websites, including social media websites. While
we try to link only to websites that share our high standards and respect for privacy, we are not
responsible for the content or the privacy practices of any third-party websites. The use of
cookies by these third parties on third parties’ websites is not covered by this Policy. We do not
have access to or control over these cookies. For this reason, we encourage you to review the
privacy policies of these websites before disclosing any personal information to or through them.
1.11.Sharing personal information
We do not sell, rent, or share your personal information except as described in this Policy. We
may share personal information, including identifiers, internet and electronic network activity,
inferences, and commercial information with:
Affiliated companies which may use this personal information to offer our services or
products to you consistent with the purposes identified in this Policy;
Our third party service providers who we have appointed as data processors to perform
functions and services on our behalf and who will be provided only with personal
information necessary to perform the services on our behalf but are not authorised by us
to use such data for any other purposes (e.g. providers of web hosting services, online
chat and email services, marketing and advertising services, social networks, data analytic
services and data enrichment services);
Judicial and government authorities or other law enforcement bodies and regulators, in
the context of complying with our legal obligations and processing requests or orders
received from those bodies;
In the event of legal proceedings, claims, complaints and other enquiries: to courts, legal
counsels or other parties where required in this context;
In the event that our business is sold or integrated with another business: to our advisers
and any prospective purchaser’s adviser and the new owners of the business.
We do not sell the personal information of minors under the age of 16 years of age.
Users of our business solutions
This section applies to you if you work for an organization which uses our business solutions or
when you use our business solutions through our mobile application interfaces (“Apps”) that link
to this Policy. The solutions we provide include project & document management software.
We use your personal information to manage our relationship with our customers – your employer – including for billing and contract management purposes, notifications related to software updates, upgrades, and system enhancements, or promote our business solutions where permitted.
We also use your information when we provide our business solutions services. If you require further information or wish to address requests about the use of your information in this context, you are advised to contact your employer directly and to review their personal data protection policy, this Policy does not apply.
2.1.Information we collect
We will collect your name, professional contact details, your job role and/or your signature in
order for us to manage our relationship with your business to perform the services agreement,
manage the contract, bill or send you product notifications or information our business solutions.
We will also need to process the following information from users: name or username, contact
details, IP address and access number. The following information will be generated by the
services: usage and traffic information including duration of meeting or event, date and time,
number of participants, web browser versions or bit rate to and from our servers and the content
recorded of meeting or events and files uploaded to the platform.
2.2.How and why we use personal information
We collect and use personal information for the following purposes: (a) to manage our
relationship with our customers, including to inform them about new CD solutions and services,
features and functionalities, (b) where necessary to protect our legitimate business interests,
which include the security of our systems and our operations, accounting, billing and audit
purposes, and the exercise or defence of legal claims, (c) to enable your communications over
the network and where necessary, to provide emergency call services and (d) to comply with our
legal obligations (for example, our obligations under telecommunication laws).
2.3.Lawful bases for processing personal information (applies only in the European Economic Area)
CD processes personal information where one or more of the following conditions that are set
out in the General Data Protection Regulation (GDPR) apply:
Where it is necessary in order for us to conduct our business and pursue our or our
affiliates’ legitimate interests for internal administrative purposes. In particular, we
collect, use and store your personal data: to communicate and manage our relationship
with our customers; to allow our customers to use our services, to ensure the security
and proper performance of our systems and our operations, for accounting, billing and
audit purposes, and for the establishment, exercise or defence of legal claims.
2.4.Sharing personal information
We do not sell, share or rent personal information except as described in this Policy.
We may share personal information with the following categories of third parties:
Our third-party service providers that help us run our business, who processes on behalf
of CD for the purposes identified above.
These providers are not permitted to use your information for their own purposes;
Your employer, to the extent this is required in order for us to perform the services and
comply with our contractual obligations towards them;
Judicial and government authorities or other law enforcement bodies and regulators, in
the context of complying with our legal obligations and processing requests or orders
received from those bodies;
In the event of legal proceedings, claims, complaints and other enquiries: to courts, legal
counsels or other parties where required in this context;
In the event that our business is sold or integrated with another business: to our advisers
and any prospective purchaser’s adviser and the new owners of the business.
Your rights and our data protection practices
3.1.Your rights
You may have specific rights based on where you live. In particular, if you are resident of the
European Union or California, USA, have particular rights, as described below. If you have
queries or a concern in relation to how we use your personal information and satisfy your rights,
please let us know by using the contact details at the end of this Policy.
3.1.1.European Union Residents
If you are a resident of the European Union, you have the right to ask us whether we hold any of
your personal information and to obtain a copy of your personal information; you have the right
to correct any incorrect or incomplete personal information; in some circumstances, you have
the right to delete personal information or restrict (stop any active) processing of your personal
information; and you have the right to obtain the personal information you provide to us with your consent in a structured, machine readable format, and to ask us to share (port) this information to another controller. In addition, you can object to the processing of your personal information in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). These rights may be limited, for example if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of these rights or to obtain other information, you can get in touch with us using the “Privacy” contact details set out below. You also have the right to complain to an EU data protection authority.
3.1.2.California Residents
If you are a resident of California, USA, and a user of our Website, you have the right to:
Request, up to two times each year, that we disclose to you the categories of personal
information that we have collected about you, the categories of sources from which your
personal information is collected, the business or commercial purpose for collecting your
personal information, the categories of personal information that we disclosed for a
business purpose, the categories of personal information (if any) that we sold about you,
the categories of third parties with whom we have shared your personal information, and,
if applicable, the business or commercial purpose for selling or disclosing your personal
information.
Request your personal information be deleted, subject to certain exceptions.
Request a copy of the specific pieces of information we have collected about you in a
readily usable format.
You can submit a verifiable request to exercise the above privacy rights using the Privacy Contact
Information set out below. We will be able to respond to your request upon verification of your
identity through a series of questions based upon information that you have previously provided
to CD. Note that only you, or someone legally authorized to act on your behalf, may make a
verifiable request related to your personal information. An authorized agent may make a request
on your behalf if: (a) the agent is registered with the California Secretary of State to conduct
business in California, has your written permission to submit the request, and verifies their
identity in accordance with the verification process; or (b) you have provided the agent with
power of attorney to act on your behalf. We will respond to your request within 45 calendar days,
after proper verification, unless we need additional time, in which case we will let you know. You
will not receive discriminatory treatment by CD for exercising the privacy rights conferred by the
California Consumer Privacy Act. Specifically, we will not: (i) deny access to our business
solutions; (ii) charge a different rate for the use of our business solutions; or (ii) provide a
different quality of service. The above rights do not apply to users of our business solutions; those
users should direct their requests to the businesses on whose behalf we provided services.
Request to opt-out of the “sale” of personal information.
We partner with third parties to display advertising on our Website or to manage our advertising
on other sites. Our Website also use third-party vendors together to report how your ad
impressions, other uses of ad services, and interactions with these ad impressions and ad services
are related to visits to our Website. This helps us make our service to you better. You can exercise
this right by clicking the link: “Do Not Sell My Personal Information” available on our Website and
setting your preferences. You will need to set your preferences from each device and each web
browser from which you wish to opt-out. This feature uses a cookie to remember your
preference, so if you clear all cookies from your browser, you will need to re-set your settings.
We do not share your Personal Information with third parties for their direct marketing purposes.
3.2.Communication Preferences
You can set and modify your communication permissions or update your contact information
using our CD Marketing Preference Center, accessible from any email we send you, or by
emailing us at [email protected] using the email address we have associated with you.
You can also opt-out or further update your email preferences through any promotional or
marketing email sent from us. These choices do not apply to transactional service
communications that are part of the CD business solutions or informational communications
that have their own unsubscribe option included in the message.
3.3.Retention of Personal Information
Where we process personal information of our customers’ employees to manage our
relationship with our customers, we do this for as long as we provide our business
solutions to our customer and for a maximum period of fourteen (14) months after this.
Where we process personal information for marketing or business analytic purposes or
with your consent, we process the data until you ask us to stop and for a short period
after this (to allow us to implement your requests). We also keep a record of the fact that
you have asked us not to send you direct marketing or to process your data so that we
can respect your request in the future.
In all other cases, we will retain your personal information for as long as this is required
to fulfill the purposes for which it was collected and for such further period required in
order to resolve disputes, to enforce our agreements, or to comply with our legal,
regulatory or contractual obligations.
3.4.Security
We provide reasonable technical and organizational security controls to protect your personal
information. However, despite our efforts, no security controls are fully effective and CD cannot.
ensure or warrant the security of your personal information. We recommend that you take every precaution in protecting your personal information when you are on the Internet. For example, change your passwords often, use a combination of letters, numbers, and symbols when creating passwords, and make sure you use a secure browser.
3.5.Transfers of personal information
Your personal information is stored on CD´s servers and the servers of our service providers
located in different parts of the world. Where information from residents in the EEA, Switzerland
or the United Kingdom is transferred to, or accessed remotely in, a non-EEA country that is not
recognized by the EU Commission as providing an adequate level of data protection, we rely on
the EU Commission approved standard contractual clauses. In some instances, where this
mechanism does not apply, we may still transfer personal information to third parties outside
the EEA after we have obtained your explicit consent for such transfer, where the transfer is
necessary in order for us to provide services under a contract for your interest, to exercise or
defend legal claims, to respond to lawful requests by public authorities, including to meet
national security or law enforcement requirements, or to fulfil compelling legitimate interests in
accordance with data protection laws. A copy of the relevant mechanism can be provided for
your review on request to the contact details contained in our Privacy Contact Information
section below.
3.6.Dispute Resolution
If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of
charge) at feedback-form.truste.com/watchdog/request.
3.7.Review of Compliance and Policy Changes
We review our compliance with this Policy on a periodic basis, and we reserve the right to update
this Policy to reflect changes to our information practices. Please check this Policy on our Website
periodically for changes. If we make any material changes, we will also post a notification on our
Website or, where appropriate, contact you via email to let you know about those changes prior
the changes becoming effective.
3.8.Privacy Contact Information
Should you have any privacy-related questions or comments relating to this Policy or the way we process your personal information, please contact us through the contact information provided
below:
Email: [email protected]
Contact Office: Central Desktop Acquisitions, Inc. PO BOX 1277 WHITE PLAINS NY 10602
Date Last Revised: Aug 10th, 2023
