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Privacy Policy

Effective: June 1, 2018

Who We Are
The pages on the Cosasco website (“the Website”) are published by Ecreativeworks, a company registered in US, whose registered address is at 213220 County Road 6, Suite 150, Plymouth, Minnesota 55441, on behalf of Rohrback Cosasco Systems, Inc (a Halma plc Company), whose registered headquarters is located at 11841 Smith Avenue, Santa Fe Springs, California, 90670 (“Cosasco”).
Cosasco and Ecreativeworks is committed to protecting your privacy. We respect your right to privacy and will process personal information you provide only in accordance with applicable privacy laws and the General Data Protection Regulation 2018.

Types of Information
Cookies. A Cookie is a randomly generated unique number placed on your computer. It allows us to identify your computer without requiring your disclosure of any Non-Public Personal Information. Cookies make it possible to both store and retrieve information through your internet browser. A Cookie itself cannot read information off a hard drive or read Cookie files from other sites. See below section regarding cookies (“The Cookies Which Are Used”) for more information.

General Information is information that does not itself reveal your identity. General Information may include, without limitation: generic business type; SIC code; information derived from publicly available databases (such as Dun and Bradstreet); user behavior on our Web site; and aggregated generic information.

Non-Public Personal Information is any non-public information you provide to us or our Partners that is proprietary or identifies or can be used to identify, contact, or locate you or someone at your business. Non-Public Personal Information may include, without limitation: name; address; phone number; e-mail address; credit card number; account information; voting behavior; spending patterns; and individual tastes and preferences.
Partners are individuals or entities we engage to help us carry out our mission.

What Information We Collect
Cosasco collects general information and non-public personal information.

How We Collect Our Information and How It Is Used
Cosasco and/or Ecreativeworks will not collect any information about individuals, except where it is specifically and knowingly provided by them.
When you visit Cosasco’s Website, web server collects some basic and general information such as your browser type, IP address, internet service provider’s domain name, which pages you accessed on the site, and when through the use of cookies and server-based tracking systems to view the usage of the Website. Details of cookies that Cosasco and Ecreativeworks uses on the Website can be found on the “The Cookies Which Are Used” section below.

Cosasco and Ecreativeworks use this information to provide you with and maintain the quality of the Website and to analyze the use of the Website in order to help guide improvements. Personally identifiable information is not automatically collected.
Non-public personal information is collected through registration or contact forms on this site and will never be used for any purpose other than internal use or by our partners unless the registrant chooses to be added to mailing lists (this is a choice made by the registrant on the Registration form).
This information will be held by Ecreativeworks. The information will be stored securely and will not be shared with third parties. By registering for the mailing lists, you consent to this use of your name and email address.

Third-party Use of Information
Except as described above, neither Cosasco nor Ecreativeworks will disclose, sell or rent your personal information to any third party. If you do consent but later change your mind, you may contact Cosasco or Ecreativeworks (as appropriate) to ask for any such activity to stop.
However, if a third party acquires all (or substantially all) of Ecreativeworks business and/or assets, Ecreativeworks may disclose your personal information to that third party following acquisition. Cosasco or Ecreativeworks may also disclose your personal information where required to do so by applicable law, by a governmental body or by a law enforcement agency.

International Transfers
Cosasco and/or Ecreativeworks may transfer the personal information that is collected from you to third-party data processors located in countries that are outside of the US in connection with the above purposes. Please be aware that countries which are outside the US may not offer the same level of data protection as the US, although the collection, storage and use of your personal data will continue to be governed by this privacy policy.
Whilst Cosasco and Ecreativeworks take appropriate technical and organizational measures to safeguard the personal information that you provide, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that the security of any personal information that you transfer over the Internet to Cosasco and/or Ecreativeworks cannot be guaranteed.

Third-party Sites
The Website may contain links to other websites operated by third parties. Please note that this privacy policy applies only to the personal information that Cosasco and/or Ecreativeworks collect through the Website and neither Cosasco nor Ecreativeworks can be responsible for personal information that third parties may collect, store and use through their website. You should always read the privacy policy of each website you visit carefully.

Privacy Policy Changes
Any updates to our privacy policy will be posted here.

Your Rights
You have the following rights:

  • the right to be provided with copies of personal information that Cosasco and/or Ecreativeworks hold about you at any time, subject to a fee specified by law;
  • the right to ask Cosasco and/or Ecreativeworks to update and correct any out-of-date or incorrect personal information held about you free of charge; and
  • the right to opt out of any marketing communications that Cosasco and/or Ecreativeworks may send you.
If you wish to exercise any of the above rights, or if you have any questions or concerns about any privacy issues, please Contact Us.

What are cookies?
When you visit Cosasco’s website, Ecreativeworks uses cookies to maintain your connection to the website. A cookie is a small file of letters and numbers that is stored on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

Cookies help Ecreativeworks to provide you with a good experience when you browse the website and also allow Ecreativeworks to improve the website. By continuing to browse the website, you are agreeing to the use of cookies. If you do not agree to the use of cookies, please stop using the website immediately.

The cookies which are used
Ecreativeworks uses the following cookies:
  • Strictly necessary cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log in to secure areas of the website.
  • Analytical/performance cookies. These allow Ecreativeworks to recognize and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognize you when you return to the website. This enables Ecreativeworks to personalize content for you and remember your account preferences.
  • Targeting cookies. These cookies record your visit to the website, the pages you have visited and the links you have followed. Ecreativeworks will use this information to make the website and the advertising displayed on it more relevant to your interests. Ecreativeworks may also share this information with third parties for this purpose.

Third-party cookies
Please note that third parties (including, for example, providers of external services such as web traffic analysis services) may also use cookies, over which Ecreativeworks and Cosasco have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. The types of third-party cookies that might be used include:

Google analytics
The Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies (text files placed on your computer) to help website operators analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the united states. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by google in the manner and for the purposes set out above.

Sharing tools
This website uses sharing tools. Sharing tools allow you to share content through social networks such as YouTube, Facebook or Twitter. When you use one of these buttons, the social networking site may place a cookie on your computer. This would be a third-party cookie set by the social networking site. If you have any questions about the use of these third-party cookies, you should check the relevant social networking site's cookie policy.

How to refuse the use of cookies
You may refuse the use of cookies by selecting the appropriate settings in your browser. However, if you do this you may lose some useful functionality such as personalization and “keep me signed in” and “remember me” features.

Each term used in this clause shall have the meaning given in the Data Protection Laws unless otherwise stated. References to "Articles" in this clause shall mean the Articles of the General Data Protection Regulation (GDPR).
The Purchaser warrants and represents that it shall, and shall procure that the Purchaser’s Personnel, process Personal Data only for the purpose of performing the Purchaser’s obligations incompliance with the Data Protection Laws.
The Purchaser warrants and represents that it shall:

(a) not do anything that would put Cosasco in breach of the Data Protection Laws;
(b) put in place before undertaking any processing and maintain appropriate technical and organizational measures in accordance with Articles 5 and 32;
(c) provide Cosasco with such assistance as Cosasco requires to ensure compliance with Articles, taking into account the nature of the processing and the information available to the Purchaser; Rohrback Cosasco Systems Terms and Conditions;
(d) maintain a record of all of its processing activities under or in connection with the Agreement and of the measures implemented under this clause in accordance with the requirements of Article 30 and make such record available to the relevant Supervisory Authority;
(e) not cause or allow Personal Data to be transferred to and/or otherwise processed in a Non-adequate Country without Cosasco's prior written approval;
(f) not transfer Personal Data to, or permit the processing of Personal Data by, any third party (for the avoidance of doubt including its Affiliates) save to the Purchaser’s employees, except:
(i) with Cosasco's prior written consent in each case (such consent to be given or withheld at Cosasco's absolute discretion); and
(ii) where Cosasco has given such consent, the Purchaser has entered into a written contract with that third party under which that third party agrees to obligations that are equivalent to the Purchaser’s obligations set out in this clause,
(g) unless required to do so by Applicable Law, in which case the Purchaser shall (to the extent permitted by Applicable Law) give Cosasco prior written notice of such requirement;
(h) at any time upon request, and in any event upon termination or expiry of the Agreement, deliver up to Cosasco or (at Cosasco's choice) securely delete or destroy all Personal Data in the Purchaser's possession (except for such Personal Data which the Purchaser is required to keep in compliance with Data Protection Laws);
(i) ensure the Purchaser Personnel are subject to binding obligations of confidentiality in respect of Personal Data processed under the Agreement.

The Purchaser shall assist Cosasco by appropriate technical and organizational measures to comply with its obligations and fulfil Data Subjects' rights under Data Protection Laws, including:

(a) responding to requests or queries from Data Subjects in respect of their Personal Data (including the provision of Portable Copies);
(b) cooperating with an investigation in connection with the Personal Data by Rohrback Cosasco Systems Terms and Conditions a regulatory body, (including a Supervisory Authority); or
(c) reconstructing and/or otherwise safeguarding the Personal Data, within any reasonable timescales specified by Cosasco.

If the Purchaser becomes aware of or suspects a Personal Data Breach it shall notify Cosasco without undue delay and in any event within 24 hours, providing all the information set out in Article 33 and/or as requested by Cosasco. The Purchaser shall at its own cost provide all assistance reasonably requested by Cosasco to ensure that Cosasco complies with its obligations under Articles 33 and 34. The Purchaser shall take all reasonable steps to mitigate any risks of a Personal Data Breach occurring in the future.
If for any reason the Purchaser is unable to provide any of the information set out in Article 33 within the time scale referred to in clause, it shall provide a written explanation to Cosasco and use all reasonable endeavors to provide all such information as soon as possible.

The Purchaser shall not disclose any information about or in connection with any unauthorized or unlawful processing or accidental loss or destruction of, or damage to, Personal Data, other than:

(a) to Cosasco;
(b) with Cosasco's express prior written approval; or
(c) as required to be disclosed by Applicable Law.

The Purchaser shall procure that all its Personnel, Affiliates and any sub-processors who have access to Personal Data in connection with the Agreement comply with the terms of this clause and the Purchaser shall be liable for all acts and omissions of such personnel, Affiliates and sub-processors.
The Purchaser warrants that from 25th May 2018, it shall, where applicable, comply with its obligations to appoint and maintain in place throughout the term of the Agreement a data protection officer as required by Articles 37, 38 and 39 and it shall designate a representative in the European Union where required by Articles 3(2) and 27 and ensure that its representative complies with clauses.

At all times that the Purchaser has access to, holds or processes any of Cosasco’s Personal Data, without prejudice to the provisions of Data Protection clause, the Purchaser shall be certified as compliant with the standards set out in ISO27001:2013 (or such replacement data security standard) by an accredited certification body and shall hold any and all of Cosasco's Personal Data in its possession in compliance with such standards.


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