Last Updated: October 7, 2022

    CITISOFT NOTICE OF COLLECTION OF PERSONAL INFORMATION AND PRIVACY POLICY UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

    Citisoft (“Citisoft” or the “Company”) is committed to maintaining the privacy and security of your personal information in compliance with California law and our Privacy Policy.

    This Notice of Collection Of Personal Information and Privacy Policy (“CCPA Privacy Notice”) applies to the collection of personal information from California residents on and after January 1, 2020. This CCPA Privacy Notice supplements our “Privacy Policy” to provide California residents with information and rights required by the California Consumer Privacy Act (CCPA).

    This CCPA Privacy Notice describes the types and categories of personal information we collect, the business purposes for which we collect, use, store and share your personal information, with whom we share it, and your rights in personal information under the CCPA.

    For purposes of this CCPA Privacy Notice, we refer to personal information according to the following definition given in the CCPA: “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information or rights that are outside the scope of the CCPA.

    By accessing our website or submitting personal information to us, you consent to the collection, use, sharing and disclosure of such information as set forth in this CCPA Privacy Notice, as it may be updated from time to time.

    What categories of personal information do we collect about you?

    • We may collect personal information from you in various ways including:
      • when you provide us with information (e.g., through your request for informational or marketing materials);
      • when you communicate with us concerning our Services;
      • when you submit an application for employment; and
      • through automated means when you use our Site including by use of “cookies” and other similar tracking technologies.

    We collect the following categories of personal information:

    • Identifiers: this information may include your name and contact details (including mailing addresses, telephone numbers, email addresses, IP address, browser or device identifier, and other identifying information you provide to us). For example, we may collect your name and email address when you join our mailing list to receive information on our Services.
    • Customer Information under California Civil Code §1798.80(e): this information comprises any information that identifies, relates to, describes or is reasonably capable of being associated with you or your household in our records. Examples include your request for information concerning our Services.
    • Characteristics of protected classifications under California or federal law: This includes demographic information, such as age, race, gender or ethnicity, or information that you may voluntarily provide to us. Our Site does not request that you provide this information.
    • Commercial Information: this category includes information concerning the Services you requested information on.
    • Internet and other electronic history: this category comprises electronic information concerning your use of the website (www.citisoft.com) and dependent pages (the “Site”). This information may include information we automatically collect as you browse the Site, including your IP address, device type or client/user identifier, browser type/identifier, operating system, pages visited, and other similar information. We may use services provided by third parties using third party cookies or tracking technology to provide us with information concerning your website activity and to provide you with advertising. For example, our web analytics provider may collect information concerning your website usage through cookies. We use information from cookies and tracking technologies (e.g., pixels, web beacons) in order to improve and customize your browsing experience, for analytics and metrics about your visits to our Site (e.g. the information concerning the length of your visit to our Site, where your visit originated from) and for marketing our Services to you. Other cookies are necessary for the Site to function properly or enhance the Site’s performance and functionality. Third party vendors use cookies and other technologies to serve ads based on your visits to the Site. Those third party cookies enable those advertisers to serve ads to our users based on previous visits to our Site and other sites on the Internet. These technologies are able to link your other Internet activity with our Site for purposes of providing you with advertising that you may be interested in.
    • We collect visitor permission for our use of cookies through a notice in the form of a cookies banner that appears on the Site that gives visitors the option to accept or decline the use of cookies. If you do not want cookies placed in your browser, you may be able to turn that feature off or permit certain types of cookies by changing the settings on your browser. Please consult your Internet browser’s documentation for information on how to do this. Please see our Privacy Policy for further information on how to opt out of certain cookies. However, if you decide not to accept essential or functional cookies, the Site may not function properly and some features may not work as they were intended.
    • Professional or Employment Related Information: if you are an applicant for employment through the Site, this information includes your work history, positions held, resumes, references and qualifications.
    • Educational Information: if you are an applicant for employment through the Site, this information includes your academic credentials, degrees, major, licenses, training and institutions attended.
    • Inferences drawn from information you provide to create a personal profile concerning your consumer preferences, characteristics, predispositions, behavior, and attitudes. We may accumulate the information you provide to develop a consumer profile concerning your behavior and interests, including for our marketing and advertising purposes, and to improve our Services. For job applicants, we may accumulate your personal information to make decisions concerning your employment related qualifications consistent with applicable law. We will use your personal information and share it with third parties solely for purposes of considering your application for employment, and should you be hired, in connection with your employment.

    In the past twelve (12) months, depending on the individual circumstances, we have collected the following categories of personal information: Identifiers, Customer Information under section 1798.80(e) of the California Civil Code, Protected Characteristics, Commercial Information, Internet History, Professional or Employment related information, Educational information and Personal Profile.

    Our Business Reasons For Collecting And Using Your Personal Information

    Depending on the individual circumstances, we collect and use personal information for the legitimate business purposes of Citisoft. These purposes include to provide you with information concerning our Services, to fulfill the purpose for which you provided us with your personal information, to communicate with you, to market our Services to you, to improve the functionality and effectiveness of our Site, to protect the security of our Site, and to comply with applicable law, rules or regulations. We may share personal information of visitors to our Site with third party advertisers for marketing purposes.

    Who we share your personal information with

    We do not sell your personal information to third parties.

    In some instances we may retain other companies and individuals to perform functions on our behalf, including, but not limited to, Information Technology and software providers, marketing and advertising providers, and web hosting platforms. Such third parties may be provided with access to your personal information to perform the functions for which they have been retained. We require our service providers, who provide services on our behalf to maintain the privacy and security of your personal information.

    We may disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, to protect ourselves from fraudulent or illegal activity, and to defend against legal claims.

    In the past twelve (12) months, depending on the individual circumstances, we have shared the following categories of personal information: Identifiers, Customer Information under section 1798.80(e) of the California Civil Code, Protected Characteristics, Commercial Information, Internet History, Professional or Employment related information, Educational information and Personal Profile with the following categories of third parties: service providers and third party businesses.

    Your rights regarding your personal information

    Under the California Consumer Privacy Act, consumers other than job applicants have the following rights in personal information held by us:

    • You have the right to request that we disclose the personal information we collect, use, disclose and share. You may request (i) the categories of personal information that we have collected about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting or sharing your personal information; (iv) the categories of third parties with whom we share your personal information; and (v) the specific pieces of personal information that we have collected about you.
    • You have the right to receive your personal information in a portable format that allows you to transmit the information to another entity.
    • You have the right to request deletion of personal information under certain circumstances. For example, we may not be required to delete personal information if we need to retain the information to complete the transaction for which the personal information was collected, perform on a contract with us, or to comply with a legal obligation. In addition, may delay deletion with respect to data stored on an archived or backup system, until the archived or backup system relating to that data is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.
    • You have the right not to receive discriminatory treatment for the exercise of any of these rights. We will not discriminate against you or refuse to provide you Products or Services because you have exercised your rights.

    You may submit verifiable requests concerning any of your rights by contacting us by e-mail tona.info@citisoft.com, by mail at the address below or by telephoning us at +1 (617) 428 9580. We will use reasonable methods for verifying that the person making a request to know, data portability or a request to delete is the individual about whom we have collected personal information. This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, you will be required to submit the request to delete, and then separately confirm that you want your personal information deleted. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.

    We will (i) confirm receipt of requests to know, data portability or to delete within 10 business days of the request; and (ii) generally respond to requests to know, data portability or to delete within 45 calendar days of the request. If we need additional time to respond to your request beyond the 45 calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional 45 calendar days to respond to your request.

    Reasonable Safeguards To Protect Your Personal Information

    We are committed to maintaining the security of your personal information in compliance with all applicable laws and our policy. We take commercially reasonable steps to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

    Access By Persons With Disabilities

    Persons with disabilities who need assistance accessing this CCPA Privacy Notice may contact us as provided for above, and depending on your individual needs, the Company will grant reasonable requests to furnish this policy in an alternative format.

    Children

    Our Site is not intended for use by children under 16 years of age. No one under age 16 may provide any information to us through the Site. We do not knowingly collect or use personal information from children under 16. If you are under 16, do not access, use or provide any information on the Site or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us. We do not sell any personal information, including the personal information of minors under 16 years of age.

    California Shine the Light Law/Online Privacy Protection Act

    California Civil Code §1798.83 provides that California residents may request certain information concerning the disclosure of personal information to third parties for direct marketing purposes. Pursuant to California Business Code §§22575-22579, you may review and request changes to any of your personal information that we have collected. Should you wish to request this information or exercise these rights, please reach us at the contact information provided below.

    We do not presently respond to Do Not Track requests. We do not control and are not responsible for third party tracking technologies that may be used on our Site. Such third parties may serve you content based on tracking you across different websites. You consent to potentially encountering third party tracking technologies when you use our Site.

    Revisions to This CCPA Privacy Notice

    We may update this CCPA Privacy Notice at any time, by posting the amended version on this Site including the effective date of the updated version. By accessing the Site or requesting information on our services after we make any such changes to this CCPA Privacy Notice, you are deemed to have accepted such changes. Please check this CCPA Privacy Notice regularly, and before you submit additional personal information via the Site.

    Contact Us

    If you have questions or comments regarding this CCPA Notice and Privacy Policy or if you would like to exercise your rights, please contact us at:

    Mail: 303 Congress St., Floor 5, Boston, MA 02210

    Email: na.info@citisoft.com

    Telephone:+1 (617) 428-9580