Effective Date: 01.19.2021
Last Updated Date: 01.19.2021
1.About this Privacy Statement
Columbia Forest Products, Inc., together with its affiliates, subsidiaries, successors and assigns (“CFP,” “us,” “our,” and “we”), is committed to protecting the privacy of individuals who visit, use, and actively enter information into the website located at [https://www.columbialegacy.com] (the “Website”) operated by CFP (collectively, “Users”). Users may at times be referred to in this Privacy Statement as “you.” This Privacy Statement describes CFP’s information practices in relation to your use of the Website. If you have any questions about this Privacy Statement, please contact CFP at info@columbialegacy.com.
PLEASE READ this Privacy Statement carefully before you use the Website. Your usage of the Website signifies to us that you have read and understood all of the terms of this Privacy Statement.
This Privacy Statement explains:
- What Personal Information we collect about you when you use the Website, why we collect it, who we disclose it to and how long we keep it;
- How we use your Personal Information we collect; and
- How we protect your Personal Information; and
- Your legal rights with respect to your Personal Information, including how to access and update the information we collect about you.
2. Modifications to this Privacy Statement
We may need to update or revise this Privacy Statement from time-to-time in response to changing legal, technical, or business developments. We will post any new or revised Privacy Statement here, and you should review this Privacy Statement regularly to make sure that you are aware of its terms. You can determine if this Privacy Statement has been revised since your last visit to the Website by referring to the effective date or last updated date at the top of this Privacy Statement. In addition, if changes are significant, we may notify you of such changes via the Personal Information (defined below) that you have provided to us, if any. If we intend to use earlier-collected Personal Information and Automatically-Collected Information in accordance with the terms of the revised Privacy Statement and doing so would result in a use for a different purpose than stated at the time of collection, where required by law we will notify you and request your consent prior to such use.
3. Personal Information You Voluntarily Provide
When you interact with us through the Website you may be asked to voluntarily provide your Personal Information in order to enable us to respond to you, or provide the features you use to interact with us through the Website. As used herein, Personal Information refers to information that identifies, relates to, describes, is associated with, or is reasonably capable of being associated with a particular individual. The most common way you will be asked to provide Personal Information to us is when you submit a contact form through the Website.
Depending on the nature of your interaction with us, the Personal Information that we may ask you to provide to us may include the following information:
- your name, email address, telephone number, and other information that could be used to contact you or identify you personally;
- information about your business or profession, including your company or job title, and business contact information including address, e-mail address, and phone number.
See additional information below regarding collection and use of your Personal Information
4. Automatically-Collected Information
CFP uses certain digital analytics tools on the Website that help us analyze site usage and performance when you visit and use the Website. The tools we use include cookies, which are discussed in more detail below. The information we collect automatically typically does not include any individuals’ names or contact information unless you have provided it to us. Rather, as you navigate and browse the Website, these analytics tools automatically collect and store information about your visit to and use of the Website, such as: the date and time of your visit, the duration of your visit, the type of browser and browser language you use, your Internet Protocol (“IP”) address, mobile device ID, type of computer or other operating device used, the actions you take on the Website (such as the web pages viewed and the links clicked, or if you abandoned a process or browsing session), the websites (if any) from which you linked to the Website, and the website(s) you visit after visiting the Website. All such information is referred to in this Privacy Statement as “Automatically-Collected Information,” and may be considered Personal Information depending on applicable privacy laws.
This Automatically Collected Information allows us to better understand the visitors to the Website, where they come from, and what content on the Website is of interest to them. It also helps us to maintain the security and operation of the Website. We may use this information to send follow-up inquiries to users who began processes on the Website that they did not complete. Otherwise, we will only ever use this Automatically Collected Information for our internal analytics purposes, to diagnose problems with our servers, and to improve the quality, performance, and functionality of the Website.
5. How We Use Voluntarily Provided Personal Information
PLEASE NOTE THAT YOU DO NOT HAVE TO PROVIDE US WITH YOUR PERSONAL INFORMATION TO BROWSE THE WEBSITE, AND YOU ARE NEVER UNDER ANY OBLIGATION TO PROVIDE YOUR PERSONAL INFORMATION. However, if you do not provide your Personal Information, you may not be able to use certain features of the Website to interact with us. BY providing us your Personal Information, you indicate your understanding that we will use that information to fulfill the purposes identified herein in accordance with the terms of this Privacy Statement and to store your information on our servers located in the United States. You understand that your Personal Information may be subject to the laws of the United States, and that it may be accessible to governments, tribunals, law enforcement and regulatory agencies in the United States.
a. Use of Personal Information to PerformServices Requested and to Contact You
CFP uses Personal Information provided by Users to perform the services they request. For example, if you submit an inquiry or interest in [CFP’s business legacy and diversification programs] we will use the information you provide to respond to your inquiry. We may also use your Personal Information to contact you regarding your use of the Website and/or to provide required notices.
b. Use of Personal Information for CFP’s Marketing Purposes
If you indicate your interest in [CFP’s business legacy and diversification programs] CFP may also use the Personal Information you provide to contact you to further discuss your interest in, and to send you information about, [CFP’s business legacy and diversification programs], which may include information about promotions or events, or that would otherwise be considered marketing information. At any time, you may request that we stop contacting you for marketing purposes by sending an email with your request to info@columbialegacy.com. Also, if we use your Personal Information to send you marketing communications via email, we will provide you with an unsubscribe mechanism to opt-out of receiving future marketing communications. If you request that we not contact you for marketing purposes (either by using the unsubscribe mechanism or by sending us an email), depending on the nature of our business relationship with you, we may still contact you for non-marketing purposes relating to your use of the Website or otherwise in regard to our business relationship with you.
For the avoidance of doubt, CFP does not share Personal Information collected through the Website with any third parties for their marketing purposes, or for any purpose other than performing services on CFP’s behalf.
c. Use of Personal Information and Automatically-Collected Information Generally
In addition to the purposes described above, we may also use both Personal Information and Automatically-Collected Information to help diagnose problems with the Website, to analyze statistical use patterns and demographic data, and to improve our products and services. We may use your Personal Information and Automatically-Collected Information to customize and tailor your experience using the Website, such as to display content in accordance with your interests and preferences.
6. Collection and Use of Automatically-Collected Information
As described above, CFP uses commonly-used information-gathering tools, such as cookies, to collect Automatically-Collected Information as you navigate the Website. CFP also uses Automatically-Collected Information to operate and improve the Website, including to track User page movement so we can recognize, improve, and deliver the desired features, content, and services that Users are most interested in. This section describes in further detail the types of Automatically-Collected Information CFP may collect and how CFP may use this Automatically-Collected Information.
a. Cookies
The Website uses an Internet browser feature called “cookies” to make your interactions with the Website easy and more meaningful. When you visit the Website, our servers send a cookie to your computer or other operating device. The cookie is placed on your hard drive or other operating device, and it assigns your computer or operating device a unique, random number that acts as a sort of anonymous ID. Standing alone, most cookies do not personally identify you; rather, a cookie identifies the computer or operating device used to access the Website. If you provide Personal Information during a browsing session some cookies enable the use of that personal information to interact with you in the future, such as notifying you if you began a website process but didn’t complete it. A cookie cannot read data off of your hard drive. Unless you choose to provide us with your Personal Information through the Website, you remain anonymous to CFP when browsing the Website; in other words, the cookie alone does not enable us to identify you personally.
Most browsers automatically accept cookies, but you can disable the acceptance of cookies at any time by changing the preferences in your browser. Most browsers also allow you to change the settings to require that the browser notify you when you receive a new cookie. Please refer to your browser for information on how to disable and control cookies. Information about managing cookies in commonly used browsers is available online from www.allaboutcookies.org. If you disable your web browser’s ability to accept cookies, you will still be able to browse the Website, but you may not be able to successfully use certain features of the Website.
b. IP Addresses and Mobile Device IDs
When you visit the Website, our digital analytics tools collect your Internet Protocol (“IP”) addresses and/or mobile device IDs to track and aggregate Automatically-Collected Information. For example, CFP uses IP addresses and mobile device IDs to monitor the regions from which Users navigate the Website in order to help us to maintain the security and operation of the Website.
7. Third Party Cookies and Website Analytics;
Third Party Analytics
We use third-party services, including [SkyGlue, Microsoft CRM, Google Analytics], to track and analyze your Website activity, as well as to track websites you visit after using the Website. In order to gather this Automatically-Collected Information, we use a Google Analytics cookie on the Website. When you visit the Website, Google Analytics automatically collects information from you through the use of Google’s analytics IDs, and Google provides some of this information to us. An analytics ID is a specific string of numbers and letters (often called a “character string”) that is assigned to your computer or device but does not name you. The analytics ID allows Google to track usage data of the Website, such as date and time of visit, duration of visit, Website traffic patterns, “clickstreams,” other similar information about your use of the Website, the type of web browser used, the operating system/platform you are using, your IP address, the websites that referred or linked you to the Website, and your CPU speed. Google Analytics does not share the analytics ID assigned to your computer or device that you use to access and use the Website. Google Analytics provides information about the use of the Website to us in aggregate form (i.e., data about many Website users combined and not just about you). Some of this data might include the regional location of Website users, but again, this data will be in aggregate (and not individual) form. We rely on this aggregate data to inform us how users are using the Website and to help us improve the Website.
8. How We Share the Personal Information We Collect
CFP may share your Personal Information in the manners described in this section. In addition, CFP may also share aggregated Automatically-Collected Information that has been de-identified or otherwise rendered anonymous without restriction.
a. Third-Party Service Providers
CFP may provide your Personal Information and Automatically Collected Information to third party service providers to perform certain services for us, including: to send communications on our behalf; to perform website analytics services, as described above in this Privacy Statement; and to provide other services relating to the operation of the Website (such as hosting, data storage, and security).
As noted above, CFP does not sell User Personal Information to any third parties. Rather, any disclosure of Personal Information to third party service providers is solely to enable the service provider to perform the requested services on CFP’s behalf. These third-party service providers are not authorized to use your information received from CFP in any way, including for their own marketing efforts, other than for the purpose of providing a service on our behalf, and are required to keep the information confidential.
b. Merger, Acquisition, or Sale
We may transfer any and all Personal Information and Automatically-Collected Information to a third party if CFP is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings in which information of Users is among the assets transferred. In this event, we will, if allowed, use reasonable efforts to notify you when your Personal Information and Automatically-Collected Information is transferred to any third party under this paragraph by posting such notice on the Website and/or by contacting you via the Personal Information you have provided us, if any. Unless you consent otherwise, we will require the third party to agree to only use your Personal Information in accordance with this Privacy Statement, even after the transfer. But any new information you provide after the transfer will likely be subject to a new policy, and you should review that policy.
c. Required by Law
Notwithstanding anything to the contrary in this Privacy Statement, CFP reserves the right to disclose your Personal Information and Automatically-Collected Information, without your consent and without additional notice to you, if we reasonably believe we are required by law, rule, regulation, judicial proceeding, court order, subpoena, or similar legal process to do so; if we reasonably believe that disclosure is necessary to protect, establish, or exercise our rights or property, or to defend against legal claims; or if we reasonably believe that disclosure is necessary to protect our other Users or our employees, property, or business, or to take action regarding illegal activities or suspected fraud.
9. Accessing, Correcting and Updating Your Information; YourRights Regarding Your Information
a. Access, Review and Modification of Information; Deleting Information
Website Users may access, update or change their Personal Information by sending us an email request to info@columbialegacy.com. If you want us to delete your Personal Information from our databases, please contact us at info@columbialegacy.com. Upon receipt of your request to delete or to change your Personal Information, we will use commercially-reasonable efforts to remove your existing Personal Information from our databases, but see the Section entitled “Retention and Storage” below regarding why we may retain some information. Please note that if we remove any or all of your Personal Information not all features of the Website may function properly.
b. Your Rights Regarding Your Personal Information
If you are based in certain jurisdictions, you may have certain rights in relation to the Personal Information we hold about you. These may include the right to request to:
- access details related to the Personal Information CFP has collected about you, for example the categories of Personal Information collected, the sources of those categories, the business or commercial purposes for collecting Personal Information, any third parties with whom Personal Information is shared, and the specific pieces of Personal Information collected about you;
- rectify any incorrect or incomplete Personal Information we hold about you
- delete, restrict, or remove the Personal Information we hold about you
- transfer the Personal Information we hold about you to another party; or
- object to the sale of your Personal Information (please note that CFP does not currently sell Personal Information, nor has it sold any Personal Information in the preceding 12 months).
We will attempt to respond to your requests within one month and free of charge. Please note that with regard to all these rights, we reserve the right to:
- verify proof of your ID to process the request, or request further information for this purpose;
- refuse your request based on the exemptions set out in any applicable data protection laws;
- charge you a reasonable administrative fee for any repetitive, manifestly unfounded, or excessive requests.
If we refuse your valid request to exercise any of these rights which you may have, we will state the reasons for our refusal and allow you to challenge our decision. If we have shared your Personal Information with others, we will inform them about your request where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly. If you wish to exercise any data protection rights that are available to you under your local data protection laws then please send your request to info@columbialegacy.com or call our corporate office at 1-800-637-1609 and we will act upon your request in accordance with applicable data protection laws.
Your California Privacy Rights
Please note, as described throughout this Privacy Statement, CFP does not disclose Personal Information to third parties for their direct marketing purposes.
Notwithstanding the above, if you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your Personal Information with third-parties. Specifically, California law provides you the right to submit a request to us at the designated address in the “Contact Us” section below to receive the following information:
- the categories of information we disclosed to third-parties for the third-parties’ direct marketing purposes during the preceding calendar year;
- the names and addresses of third-parties that received such information; and
- if the nature of a third-parties’ business cannot be reasonably determined from the third-parties’ name, examples of the products or services marketed.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually.
10. Children’s Privacy
The Website is not directed at nor intended for use by children under the age of 13. Further, CFP will never use or disclose any Personal Information of a child under either the age of 18, or the age of majority in jurisdictions where such age is greater than 18, for marketing or advertising purposes. If you are under age 18, or under the age of majority in jurisdictions where such age is greater than 18, you should not provide CFP with Personal Information about yourself if you use the Website. If we learn that we have received Personal Information or Automatically-Collected Information from a child under either the age of 18, or the age of majority in jurisdictions where such age is greater than 18, we will delete that information from our files.
11. Security of Collected Information
CFP uses commercially-reasonable physical, electronic, and administrative security measures to assist in protecting against the loss, misuse, and unauthorized alteration of Personal Information that is under our control. Unfortunately, no data storage system, or system of transmitting data over the Internet or wireless network, can be guaranteed to be 100% secure, and no security system can prevent all security breaches. As a result, we do not and cannot guarantee the security of our servers or any Personal Information or Automatically-Collected Information provided to us in connection with your use of the Website.
12. Do Not Track
The Website does not track your online activities across third-party websites or services, and so does not respond to browser “Do Not Track” signals. If you browse other websites, these websites may set cookies that obtain information about the fact that a web browser visited the Website from a certain IP address. These websites are not authorized to collect any other personal data from the Website unless you provide it to them directly.
13. Retention, Storage and Removal
We may retain all Personal Information and Automatically-Collected Information in our databases for long as necessary to perform the business purposes for which we’ve collected it, or until you ask us to remove your information from our databases, unless applicable laws permit or require otherwise. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or aggregate it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. Note that even after you ask us to remove your information from our databases, it may be impossible to remove some information, such as information tracked in our web server log files and information that may reside in backup files. We retain this residual information to preserve the integrity of our back-up files and for business continuity purposes. We may also retain Automatically-Collected Information even after you request that we remove your information from our databases, for use in the aggregate and to analyze and improve the Website.
Further, even after you request that we remove your information from our databases, we may retain Personal Information and Automatically-Collected Information to comply with any applicable law, rule, regulation, or guideline; to prevent fraudulent activity; to protect ourselves against liability; as well as to allow us to enforce our contractual or other rights, and to pursue available remedies and limit any damages we may sustain.
14. Contacting Us
Questions regarding this Privacy Statement or the information practices pertaining to the Website, including our information practices related to our use of or disclosures to Sales Agents and service providers, should be directed to info@columbialegacy.com or by contacting us using the information below:
By Phone to our Corporate Office: 1-800-637-1609
By mail to:
Columbia Forest Products
C/O Columbia Legacy
Information Privacy
7900 McCloud Road
Suite 200
Greensboro, NC 27409
