Privacy Policy
Last updated September 15, 2024
This Privacy Policy (“Policy”) describes how CullWell Technologies LLC (“CullMaster”, “we”, “us”, “our”) collects, uses, shares, and retains your information when you visit our websites and mobile applications, as well as the rights you have with respect to your personal information and how to exercise those rights.
This Policy describes our practices regarding personal information. This Policy applies to our websites that link to this Policy, and to our other interactions with you where this Policy is provided. This Policy does not apply to websites, applications or other points of contact that have a different privacy policy posted or otherwise available.
Information that We Collect
Categories of Personal Information
The personal information that we collect about a specific individual, and the sources we use to collect that personal information, will depend on our relationship or interaction with that individual. The following are the categories of personal information that we may have collected about you and examples of the personal information that fall into these categories:
1. Personal Identifiers, such as name, date of birth, postal address, email address, online identifier, phone number, or other similar identifiers.
2. Personal information as defined in the California customer records law, such as signature, telephone number, and financial information such as account number and balance, payment card details including credit and debit card numbers.
3. Commercial Information, such as products and services obtained and transaction histories. Depending on the product or service you have with CullMaster or a party with whom CullMaster has a business relationship, this may include information about:
· Subscriptions or recurring transactions only authorized by you.
· A device, equipment, or consumer product related to a CullMaster product or service (such as serial number, a mobile device international mobile equipment identifier (IMEI) and other device information, or details about a connected device).
4. Internet or network activity information, such as IP address, browsing history, and information regarding your interaction with CullMaster websites, mobile applications, or advertisements.
5. Geolocation data, such as device location, including where necessary to provide the product or service you requested and as disclosed to you as part of that product or service purchase.
6. Audio, electronic, visual and similar information, such as call and video recordings.
7. Inferences drawn from any of the above to create a summary about, for example, an individual’s preferences and characteristics. However, this information is not used for solely automated decision making. See the section “No Profiling” below.
Sources of Personal Information
We collect personal information from:
· individuals directly, or from other individuals, agents or companies acting on their behalf.
· our affiliates and subsidiaries.
· public records or widely available sources, including information from records and information made available by federal, state, or local government entities.
· companies with whom we have a business relationship, and from whom you have purchased a product or service that makes you eligible for a CullMaster product or service.
· other companies and organizations, such as advertising partners, recruiters, social media networks, data brokers, insurance carriers and other service providers (including entities that assist us with data analytics, and marketing).
· your computer system or mobile device when you visit our websites.
We may combine information we collect with information obtained from other sources.
How Long We Keep Personal Information
The amount of time we retain a particular category of personal information will vary depending on the purpose for which it was collected, our business need for it, and our legal obligations with respect to it. We retain your personal information for the time needed to fulfill the purpose for which that information was collected and to adhere to our policies on keeping records. Our retention policies reflect applicable statutes of limitation periods and legal requirements. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.
Why We Collect Personal Information and How We Use It
The purposes for which we collect and use personal information depend on our relationship or interaction with you. If we are interacting with you on behalf of another business entity (e.g. a financial institution or commercial retailer) we will collect and use your personal information only as permitted by the terms governing our relationship with that business entity. Otherwise, we may use personal information for the following business purposes:
· Provide and maintain your services and products. We may use your personal information to create, maintain, customize, and secure your account with us, provide you with features or services or otherwise register you with our services. We may also use your personal information to process your requests, purchases, transactions, payments and prevent transactional fraud.
· Improve, develop and analyze our websites, services and products. We use your personal information and other information to:
· analyze, improve, develop or deliver our websites, products and services and develop new services, products or features using algorithms, analytics software and other similar methods,
· conduct actuarial or research studies to maintain, protect and develop our networks, services, and products and protect our customers, and
· analyze how visitors use our websites to improve the websites and enhance and personalize your experience.
We collect some information used for these purposes using analytics software, cookies and other tracking technologies. For more information about the collection and use of this information, see Data Technologies below.
· Communicate with you about your service or product. We may communicate with you about your account or transactions with us, respond to your comments, questions or requests, provide customer service, provide you with notices or other communications, and send you information about features on our websites, applications, or other services or changes to our policies. With your consent, we may also post your testimonial along with your name and other information on our websites or other media channels.
· Provide marketing communications. We may use your personal information to send you marketing communications (including newsletters, e-mails, direct mail, and phone calls), to send you offers and promotions for our products and services, and to personalize content and experiences on our websites or applications.
· Comply with legal requirements and protect the safety and security of our business, services, and websites. We may use your personal information to comply with laws, regulations or other legal obligations, to assist in an investigation, to protect and defend our rights and property or the rights of third parties or enforce terms and conditions. We may also use your personal information to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse or for any other reason permitted by law. We may use your personal information to protect our company, our affiliates, our customers, our network and our websites.
· Update or correct our records. We may receive personal information about you from other sources, including publicly-available databases, affiliates or third parties from whom we have purchased data, and combine that personal information with other personal information we have about you to update our records. For example, we may obtain change of address information from public sources and use that personal information to update or correct your address information.
Sensitive Information
CullMaster does not collect, use, or disclose sensitive personal information, as such term or a similar term is defined by applicable privacy law, other than as permitted by law or with your consent (where required).
No Profiling
CullMaster does not use personal information to evaluate, analyze or predict personal aspects related to an individual’s economic situation, health, preferences, interests, reliability, behavior, location or movements, or performance at work, which is also known as profiling, in furtherance of decisions that produce legal or similarly significant effects solely through an automated process that do not require final review and decision by a human.
Disclosure of Personal Information to Others
In the past twelve (12) months, we may have disclosed personal information included under the categories listed above for our business purposes to:
· Regulators, law enforcement and other government entities;
· Our affiliates and subsidiaries;
· Vendors who provide services to us;
· Entities who provide Targeted Advertising services or through which we purchase target ads;
· Business partners, clients, agents, and brokers;
· Credit bureaus;
· Researchers (such as for actuarial or research studies) and professional advisers (such as lawyers and accountants); and
· In connection with a sale or transfer of all or part of our business.
As is common practice among businesses that operate Internet websites, within the past twelve (12) months, we may have shared certain identifiers such as email addresses and pseudonymized identifiers, information about the use of our websites, and inferences drawn about you to our social media, advertising, and analytics partners for data analytics and Targeted Advertising purposes.
We do not knowingly collect personal information from, or knowingly market products or services to, any person under the age of 18. We do not disclose personal information of individuals we know to be under the age of 18 to third parties for Targeted Advertising.
Data Technologies
Our websites may use various technologies, including cookies, tokens, tags, web logs, web beacons, widgets, plug-ins, scripts, chat and chatbots, and web server logs to automatically gather information about you and about your use of the Services (collectively, “Data Technologies”). A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "web beacon" also known as an Internet tag, pixel tag or clear GIF, links web pages or apps to web servers and may be used to transmit information back to a web server.
The types of cookies placed by our websites fall into any one of the following categories:
· “Strictly Necessary” cookies are necessary for the website or application to function and cannot be switched off in our systems. They are usually set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You do not have the option to disable Strictly Necessary cookies.
· “Functional” cookies enable the website or application to provide enhanced functionality and personalization based on your interaction with the website or application. These also allow us to track analytics by counting visits and traffic sources so we can measure and improve the performance of our websites and applications. They may be set by us or by service providers to help us to know which pages or content are the most and least popular and see how visitors move around the website or application. If the website you are visiting presents you with a cookie banner, functional cookies will be placed only if you accept such placement.
· “Advertising” cookies may be set by us or through our websites and applications by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other websites. Advertising cookies will be placed only if you accept such placement. Also refer to the section of this Policy titled “Your Targeted Advertising Options”.
We may combine information received from the Data Technologies about visitors to our websites or use this information to enable certain features of our services. Depending on the Data Technologies you’ve enabled, this information may include demographic data, technical information about the technology (e.g., phone, computer) you use to connect to the online services, web browser information, your IP address, geolocation of your mobile device, and browsing behavior such as pages visited and how often they are visited.
Depending on the Data Technologies you’ve enabled, we allow service providers and third-party companies to use Data Technologies to collect the information described above and to track browsing activity over time and across third-party websites, such as web browsers used, which websites are referring traffic or linking to our online services, to support data analytics or, in some instances, to deliver targeted advertisements to you. We do not control these third-party technologies, and their use of such technologies is governed by their own privacy policies.
The length of time cookies will stay on your device will depend on whether it is a “persistent” or “session” cookie. A persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless deleted by you before the expiration date. A session cookie, on the other hand, will expire at the end of your web session, when the web browser is closed.
Email and Text Communications
We may also use Data Technologies to determine whether you have read, clicked on, or forwarded certain email or text communications we send to you so that we can make our communications more helpful and interesting.
You can unsubscribe from our emails or text messages by following the instructions in the email or text communications you receive from us.
Your Targeted Advertising Options
If you’ve enabled the placement of Advertising cookies, we partner with third parties to provide advertising services that are targeted based on your online activities across websites, mobile apps, and devices over time (referred to as “Targeted Advertising”) to enable us to send you Targeted Advertising both on our websites and on third party websites.
Regarding cookies, the preference you select is limited to the website for which you’ve made the preference selection and does not apply to other websites or any other pages. In addition, third party advertisers may use and disclose information gathered through Data Technologies for their own purposes, subject to their own privacy policies. Several advertisers participate in the Digital Advertising Alliance, and you can opt-out of the delivery of Targeted Advertising to you by the participating advertisers by visiting: https://youradchoices.com/pmc
To prevent Targeted Advertising by or on behalf of CullMaster you may:
· Click the “Decline All” option presented on a posted “cookie banner” on the website homepage.
· Click the link titled “Do Not Sell or Share My personal information” on the website homepage.
· Opt-out of certain Data Technologies by managing your preferences in the website’s cookie manager preference center.
· Use a Do Not Track Signal. To the extent required by law, CullMaster will honor signals that you have enabled that communicate your choice to opt-out of the placement of Advertising cookies.
If you have not enabled the placement Advertising Data Technologies, you may still see advertisements from CullMaster, but these ads are not based on our tracking of your internet browsing activity across third-party websites.
Your Privacy Rights
Under certain state laws, you may have the following rights:
Right to Know: the right to request we disclose to you the following:
1. Whether we are processing personal information about you.
2. The categories of personal information we collected about you.
3. The categories of sources from which we collected the personal information.
4. The business or commercial purpose for collecting, sharing, and using personal information about you.
5. The categories of third parties to whom we disclosed personal information about you.
6. The specific pieces of personal information we collected about you.
Right to Correct: the right to request that we correct inaccurate personal information that we maintain about you.
Right to Delete: the right to request that we delete personal information we, or an entity acting on our behalf, collected about you.
Right to Opt-out of the Sale or Sharing of personal information: We do not sell your personal information in exchange for monetary value; however, we may share your personal information for Targeted Advertising purposes if you’ve enabled the placement of Advertising Data Technologies. See the section “Your Targeted Advertising Options” above. You can opt-out of our sharing your personal information with third parties for the third parties’ direct marketing purposes. To find out more about your opt-out rights, please see “How to Exercise Your Privacy Rights” and “How to Contact Us”.
We will not discriminate against any consumer who exercises any of their privacy rights found under this Policy by denying a good or service, charging a different price or providing a different level of quality or service. However, we may charge a consumer a different price or rate or provide a different level or quality of goods or services to the consumer, if that difference is reasonably related to the value provided to the business by the consumer’s data. Also note that certain choices, such as disabling cookies, may prevent you from using certain features on our websites.
How to Exercise Your Privacy Rights
You may exercise your privacy request rights by:
Emailing: CullMasterHelp@cullmaster.com
Visiting this page on our website: https://cullmaster.com
Mailing: 414 Watch Hill Lane, Louisville, KY 40245
You must provide sufficient information that allows us to reasonably verify you are the person who is the subject of the rights request, or such person’s authorized representative. We may limit our response to your exercise of your rights as permitted under applicable law.
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. If an agent makes a request on your behalf, as permitted by law, we may require verification of the agent’s authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, or require you to verify your own identity. This may include, but is not limited to, a notarized financial/general power of attorney, court order, or official proof of guardianship.
Upon receiving your request, we will confirm receipt within ten (10) business days and respond to a verifiable consumer request within the timeframe and in the format required by relevant law.
If we are unable to honor your request, we will provide you with a written explanation of the reason(s). You have the right to contact us in writing if you wish to appeal our decision and we will provide you with a written response.
Protection of Personal Information
We use administrative, technical, and physical security measures to protect your personal information and take reasonable steps to securely destroy or permanently de-identify personal information when we no longer need it. Despite these measures, we cannot guarantee the security of networks, servers, and databases over the Internet. Therefore, although we work to safeguard your privacy, we cannot promise, and you should not expect, that personal information or communications you transmit via the Internet are guaranteed to remain secure.
Notice to Persons Accessing this Website outside the United States
If you reside outside the United States, any information you provide to us through this website may be transferred out of your country and into the U.S. If you do not want your information, including personal information, to leave your country, do not provide the information to us. By providing information to us, you explicitly consent to the transfer of your information to the U.S. Personal information collected on this website may be stored and processed in the U.S. or any other country in which we or service providers maintain facilities.
Updates to this Policy
We may modify this Policy from time to time. When we make material changes to this Policy, we will post a link to the revised Policy on the homepage of our websites. You can tell when this Policy was last updated by looking at the “Last updated” date at the top of this Policy. Any changes to our Policy will become effective upon posting of the revised Policy.
How to Contact Us
If you have any questions or comments about this Policy, or if you would like us to update information we have about you or your preferences, please contact us as indicated below.
CullWell Technologies LLC
Attn: Privacy Office
414 Watch Hill Lane
Louisville, KY 40245
Copyright © 2024 CullWell Technologies, LLC - All Rights Reserved.
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