Privacy Policy

 

Overview:

Computer Enterprises, Inc. (“CEI”, “us”, “we”, or “our”) provides Information Technology consulting and outsourcing services to businesses in the United States. CEI operates the http://www.ceiamerica.com/ website (hereinafter referred to as the “Service”). This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve our services. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy apply to all interactions occurring within the use of our Service.

 

Scope and Compliance:

In the operation of its business, CEI recognizes and respects the privacy rights of all individuals. In order to protect the privacy of individuals with whom CEI comes in contact through its business activity. As of September 20, 2019, CEI has updated its privacy policies in accordance with the following established and required guidelines:

 

California Consumer Privacy Act (CCPA):

Broadens scope to include personal information identifiable to households and provides consumers ability to prevent sale of personal data of residents of California.

 

General Data Protection Regulation (GDPR):

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. CEI aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

This Privacy Statement applies to all personal data (as defined below and by applicable laws in California, the EEA/EU Member States and Switzerland) received by CEI in any manner including but not limited to in electronic, paper or verbal form. On occasion and pursuant only to its business practices CEI may act as a data controller and/or data processor on its own and/or on behalf of its customers within the terms further outlined below. When acting as a data controller and/or a data processor, CEI does not retain independent rights to control the use of personal data it processes on behalf of its customers; it acts solely on its customers’ instructions. CEI handles all personal data in accordance with the principles established by the CCPA, GDPR, and Pennsylvania state laws whether collected on its own, via its website (www.ceiamerica.com), or as a result of performing services for its customers.

 

Definitions:

The following definitions apply to this Privacy Statement:

Service: Service is the https://www.ceiamerica.com/ website operated by CEI

Personal Data:  Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). It also includes information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Sensitive Data: Sensitive data as used herein is defined as personal data treated in European data protection laws as posing a special risk to individuals such as information about racial or ethnic origins, political affiliations, religious or philosophical beliefs, trade-union membership, government-issued identification numbers, healthcare or lifestyle choices.

Usage Data:  Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies:  Cookies are small files stored on your device (computer or mobile device).

Sensitive Data:  Sensitive data as used herein is defined as personal data treated in European data protection laws as posing a special risk to individuals such as information about racial or ethnic origins, political affiliations, religious or philosophical beliefs, trade-union membership, government-issued identification numbers, healthcare or lifestyle choices.

Data Controller:  Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purposes of your visit, CEI functions as a data controller on the wesbite.

Data Processors (or Service Providers):  Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User):  Data Subject is any living individual who is using our Service and is the subject of Personal Data.

 

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you or individuals within your household or business entity (“Personal Data”). Personally identifiable information collected on our website at this time is limited to:

  • Email address (Only if Contact/More Information is requested by visitor)
  • First name and last name (Only if Contact/More Information is requested by visitor)
  • Phone number (Only if Contact/More Information is requested by visitor)
  • Usage & Cookies Information (as specified below)

Visiting www.ceiamerica.com does not require registration of any kind.

Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data
CEI does not engage in any activity that will personally identify visitors to its website except as set forth below.

CEI may use a site visitor’s IP address to help diagnose problems with CEI servers, to administer its website and to refine its website based on which features people use most often. IP addresses may also be used to help gather broad demographic information.

In addition, CEI may use session cookies to track visits to its website. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.)
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data
CEI uses the collected data for various purposes:

  • To provide and maintain our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues

Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

 

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), CEI legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

CEI may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • To comply with the law

 

Retention of Data

CEI will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

CEI will also retain Usage Data for internal analysis purposes. Usage Data is generally
retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

 

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

 

Notice and Choice

When CEI collects personal data, CEI always provides individuals with notice that it has collected personal data and provides them with an option to have their personal data kept confidential and/or destroyed.

Occasionally, the collection of personal data does not require the explicit consent of the individual whose personal data may be collected. In addition, CEI may send unsolicited emails to individuals in the regular course of business. In such cases, CEI informs such individuals about the possibility of disclosures to third parties of their personal data including sensitive personal data. CEI offers such individuals the opportunity to choose from the following options (or to opt out): (1) to stop receiving emails and to have their personal data destroyed; (2) to allow their personal data to be disclosed to a third party; or (3) to allow their personal data to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized.

 

Security

CEI employs accepted standards and procedures for security of data, networks, infrastructure and applications which are designed to safeguard and secure personal data and sensitive data against loss, misuse, theft, unauthorized access, disclosure, alteration and destruction. However, CEI does not guarantee the security of data transmitted through the internet.

When acting as an agent processing personal data under the direction of its customers, CEI enters into agreements with its customers specifying the conditions under which personal data can be processed and kept secure.

 

Data Integrity

CEI takes reasonable steps to ensure that personal data is accurate, complete, current and reliable for its intended use. CEI limits its collection of personal data to that which is relevant for its business and legal purposes. CEI does not use the data in a way that is incompatible with the purposes for which it was collected and/or subsequently authorized by the individual.

If an individual believes that his or her personal data is stored in CEI’s database(s) or is otherwise in the possession of CEI, and wishes to correct, amend and/or delete such data therefrom, requests can be emailed to privacy@ceiamerica.com. The words “Data Integrity” should be put in the subject line of the email. CEI will honor all such requests in a timely manner except where there is a significant burden or expense associated with doing so or where others’ rights may be violated.
When CEI acts as an agent of its customers, CEI usually has no direct relationship with the individuals whose personal data it processes. In such cases, the request to access, correct, amend and delete personal data should be sent to the entity to which the information was originally provided.

 

Disclosure of Data

CEI discloses personal data only under the following circumstances: to third-party contractors or agents that process the data on CEI’s behalf; to satisfy government reporting requirements; to meet other legal obligations as described below; or with the consent of the individual. Before making disclosures to a third party, CEI first applies the Notice and Choice principles as described below. CEI also ensures that the third party to whom the disclosure is made is obligated (by law, contract, or its own CCPA, GDPR or Pennsylvania privacy regulations) to provide at least the same level of privacy protection as is required by this Privacy Statement. Where CEI contracts with third parties to process personal data on its behalf, CEI’s policy is to contractually obligate the third parties to maintain the confidentiality and security of the personal data; to act upon it only in accordance with the instructions received from CEI and/or its client; and to handle the information strictly in accordance with these principles.

 

Legal Requirements

CEI may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of CEI
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

 

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)/California Privacy Protection Act (CPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. CEI aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at privacy@ceiamerica.com with the subject “GDPR”.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where CEI relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

  • Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

 

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

Enforcement, Limitations, and Compliance

Enforcement

CEI uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies that the policy is accurate, prominently displayed, completely implemented and accessible. CEI will cooperate with California privacy enforcement authority, the European Data Protection Authorities, the U.S. Department of Commerce, the U.S. Federal Trade Commission, relevant state or provincial agencies, and law enforcement and judicial authorities in investigating any privacy complaints or suspected violations of applicable privacy laws. CEI will rectify any non-compliant practices as they are discovered.

Limitations

CEI’s adherence to the CCPA, GDPR or other applicable privacy principles may be limited to the extent necessary to meet national security, public interest or law enforcement requirements.

Compliance

CEI uses an annual self-assessment program to verify that the attestations it makes under CCPA, GDPR, and applicable privacy policies are true and that its privacy policies are being followed in practice. In addition, CEI will cooperate with European Data Protection Authorities to resolve any complaints that may arise in relation to personal data transferred under GDPR.

Changes to This Privacy Policy

This Privacy Statement may be amended from time to time, consistent with the requirements of CCPA, GDPR, or Pennsylvania privacy protection laws. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via a prominent notice on our landing page, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Point of Contact

Questions or concerns about this Privacy Statement or CEI’s data collection and processing practices can be emailed to privacy@ceiamerica.com. Please put the applicable policy in the subject line of the email (“CCPA”, “GDPR” or “Questions”).