Concentric Technology Solutions, Inc.
Privacy Policy
Effective Date: 7/22/2023
We appreciate your interest in our products and services (collectively, our
“Services”). Privacy protection is very important to us and we are committed to protecting
you and respecting your privacy. This Privacy Policy sets out information about how we
collect, store, process, transfer and use data that identifies you or makes you identifiable,
as a natural person (hereinafter “personal information”).
This Privacy Policy is designed to be used for our website visitors and users of our Services
on a global basis. The Privacy Policy will thus provide various information that is required
in specific jurisdictions only. We have in the following marked with “GDPR Notice”, the
information applying to our activities only subject to the GDPR and marked otherwise the
notices specifically required under other laws
Who is data controller of your personal information
We, that is Concentric Technology Solutions, Inc. (CTS Corp), is the data controller. We are
responsible for, and control, the processing of your personal information.
If you wish to contact us, you can find our contact details at the end of this Privacy Policy.
What information do we collect
When you use our Services, we may collect information about you. This information
regularly includes the following.
• If you order any Services from us or ask for a quote: Name, company, shipping and billing
address, email address, phone number, fax number, job title, information from our
correspondence with you; information on your order or quotes, such as price and parts
information, information on the return of shipment, defects or erroneous products, your
feedback and complaints, quotes we offer you, customer ID, information on your TTI
customer account; payment information such as bank account details, credit card
information, or check information; information on outstanding payments; VAT number.
• If you register on our website: Name, company, address, email address, password, phone
number, job title; as well as any kind of information you provide us with.
• If you contact us (via our website or via phone, email or letter): Name, company, job title,
industry, address, email address, phone number, fax number, and any additional information
you provide us with.
• If you use our website: IP address, browser data, browser type, device type, device ID,
Uniform Resource Locators (URL), operating system, part search and detail requests,
information on your usage of our website.
• If you are in our email marketing campaigns: name, email address, title, address, industry,
region, information whether you are already a customer, marketing campaign information,
such as your reaction to our marketing and your interest in our Services.
How do we collect your information
This personal information is collected from you may include:
• Personal information you provide to us: The majority of personal information we receive
comes to us voluntarily from our users in the course of using our Services, such as when
visiting our website, communicating with us or in the ordering process.
• You are free to choose which information you want to provide to us or if you want to provide
us with information at all. However, some information, such as your shipping address,
payment information and product order information are necessary for the performance of
our contractual obligations. Without providing this information, you will not be able to order
product or services from us.
• Personal information collected via technology: As you use our websites, we may collect
passive information through the use of cookies. Please see below for more information.
Why and on which legal grounds do we collect and use your personal information:
The reasons for using your personal information may differ depending on your interaction
with us. Regularly we use your information for the following purposes and on the following
legal grounds:
• We use your information in order to perform our contractual services or prior to entering
into a contract with you. If you order product or services at CTS Corp or if you contact us to
order product or services, we use your information to provide you with our products
services. Information we use for this purpose includes: information we need to contact you
and communicate with you; information we need in order to provide you with individualized
offers (repricing, quoting); information to manage and execute your orders, also in the
context of warehousing and shipping; information in the context of a possible return of your
products or services and the evaluation of defects; information for invoicing; information
provided in the context of using our online applications and payment follow up. The legal
justification of these data processing activities is the need to perform a contract with you or
to take steps at your request prior to entering into a contract. The data will be stored as long
as it is necessary for the performance of the contract.
• We use your information if justified by our legitimate interests. The usage of your
information may also be necessary for our own business interests. For example, we may
use some of your information to evaluate and review our business performance, for
advertising purposes or to identify potential cyber security threats. If necessary, we may
also use your information to pursue, or defend ourselves against, legal claims. If you use our
website, we may also use your information to provide and improve our website services. We
have a legitimate interest in performing these tasks as they are relevant for conducting our
business. The legal justification of these data processing activities is thus the balancing of
interest-based justification. The data will be stored as long as it is necessary for pursuing
our legitimate interests.
• We use your information after obtaining your consent. In some cases, we may ask you to
grant us separate consent to use your information. You are free to deny your consent and
the denial will have no negative consequences for you. You are free to withdraw your
consent at any time with effect for the future and the withdrawal will not have negative
consequences for you. If you have granted us consent to use your information, we will use it
only for the purposes specified in the consent form. This especially includes our marketing
campaigns. If you sign up to our email newsletter or, when providing us with your email
address, allow us to use this email address for email marketing, we will use your information
in our email marketing campaigns. You may unsubscribe from our email newsletter at any
time by clicking on the “unsubscribe link” provided in such communications or by sending an
email to [email protected]. The legal justification of such data processing
activities is the consent you are granting us. If we use your email address for our email
newsletter, we generally store the data until you unsubscribe from our newsletter. However,
the legal justification to keep data stored for other purposes, e.g. keeping a blacklist to
safeguard e-mail addresses will no longer be used for marketing purposes after
unsubscribing, remain unaffected by this. The data will be stored as long as it is necessary
for the data processing activity.
• We use your information to comply with legal obligations. We are obligated to retain certain
information because of legal requirements, such as for tax and business regulations, for
example, tax or commercial laws. The legal justification of such data processing activities is
our need to comply with applicable legal obligations. We store this data as long as we are
required by law to do so. In this regard, statutory retention periods may require us to store
your personal information for up to ten years.
We will only use your information for the purposes above. We will not use your information
for other purposes. We do not use your personal information for automated individual
decision-making.
With whom and on which legal grounds do we share your personal information
As required in accordance with how we use it, we will share your personal information with
the following third parties:
• Delivery agents: to ship your orders, we may share your name and shipping address with
delivery agents, such as FedEx, UPS, or DHL. The legal justification of data transfers is our
duty to perform the contract with you.
• Service providers and advisors: third party vendors and other service providers that perform
services for us or on our behalf, which may include marketing campaign services, providing
mailing or email services, tax and accounting services, product fulfilment, payments
processing, data enhancement services, fraud prevention, web hosting, or providing analytic
services. Any such service providers and advisors will be given limited access to personal
information as reasonably necessary for delivering its service and will, by appropriate data
processing agreements, be bound to only process personal information on our behalf and
under our instructions. The legal justification of such data transfers is either the
performance of the contract with you or the balancing of legitimate interests.
• Purchasers and third parties in connection with a business transaction: personal
information may be disclosed to third parties in connection with a CTS Corp-related
transaction, such as a merger, sale of CTS Corp assets or shares, reorganization, financing,
change of control or acquisition of all or a portion of our business by another CTS Corp entity
or third party, or in the event of a bankruptcy or related or similar proceedings. We have a
legitimate interest in transferring data in connection with a business transaction. The legal
justification of this data transfer is the balancing of interest; and
• Law enforcement, regulators and other parties for legal reasons: third parties as required by
law or subpoena or if we reasonably believe that such action is necessary to (a) comply with
the law and the reasonable requests of law enforcement; (b) to enforce our legal claims or to
protect the security or integrity of our Services; and/or (c) to exercise or protect the rights,
property, or personal safety of CTS Corp, our visitors, or others. We are legally obliged to
transfer the data in this scenario. The legal justification of such data processing activities is
our need to comply with applicable legal obligations.
If you are a resident of the State of Nevada in the United States, Chapter 603A of the
Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain
covered information that a website operator has collected or will collect about the
resident. To submit such a request, please contact us at [email protected].
How long do we keep your information
We will store personal information for as long as necessary to fulfil the purposes for which
we collect the personal information in accordance with our legal obligations and legitimate
business interests. To ensure that all your data is deleted in accordance with the principle
of data minimization, we have developed a data retention policy. The following describes
the fundamental principles and outlines essential retention periods contained in this policy.
As a general rule, we keep data necessary for the performance of a contract for six up to
ten years depending on the nature and scope of the contract in order to clarify any enquiries
or claims after expiry of the contract. We need this information, e.g. in the context of a
possible return of your Services and the evaluation of defects or for compliance with
statutory retention requirements, for example, tax laws.
We may retain any information that we deem necessary to investigate or defend claims
against us, or to prosecute or bring claims against you, us or any third party, for as long as
we believe such action may be necessary.
We may retain data collected from you for customer service and marketing purposes, for up
to six years after collection, unless you object against the procession of your data for this
purpose or you wish the data to be deleted and there are no contractual or statutory storage
obligations that prevent this request for deletion.
In regard to business correspondence or documents relevant under commercial code or tax
law, statutory retention periods range from six up to ten years. This legal data retention
period covers, inter alia, invoices, vendor documents or financial statements.
We may store your device information and other technical information for legitimate
business purposes.
How do we protect your information
We have implemented appropriate technical and organizational measures to protect your
personal information against accidental or unlawful destruction, loss, unauthorized change
or damage. All personal information we collect will be stored on our secure servers. All
electronic transactions entered into via our website will be protected by SSL encryption
technology.
What kind of cookies and tracking technology do we use
We, and our third-party partners, automatically collect certain types of usage information
when you visit our Services, read our emails, or otherwise engage with us. You can usually
change the settings of your browser to modify the permissions you give to us and third
parties for the storing of and gaining access to cookies on your device.
• What are Cookies? Cookies are text files, containing small amounts of information, which
are downloaded to your browsing device (such as a computer, tablet or mobile phones)
when you visit a website. Cookies allow websites or ad networks to recognize a user’s
internet browser. This helps websites to know if the browsing device has visited them
before.
• What are Cookies used for? Cookies do lots of different jobs, like helping us understand how
our website is being used, letting you navigate between pages efficiently, remembering your
preferences and generally improving your browsing experience. Cookies can also help
ensure marketing you see online is more relevant to you and your interests.
• What types of Cookies are used by CTS Corp and on which legal grounds do we process
personal information? The types of cookies used on our site can generally be put into one of
the following categories: strictly necessary; analytics; functionality; advertising; and social
media. You can find out more about each of the cookie categories in the description below.
o Strictly Necessary Cookies: These cookies are essential to make our website
work. They enable you to move around the site and use its features. Without these
cookies, services that are necessary for you to fully use our website may not be
available, such as accessing certain areas of the website. We have a legitimate
interest in the use and storage of these cookies for the technically flawless and
optimized provision of our Services and to carry out the electronic communication
process in the functions you require.
o Analytics Cookies: These cookies are used to deliver advertisements that are more
relevant to you and your interests. Please see the section below on “Online
Advertising and Data Collection.”
o Functionality Cookies: These cookies allow us to remember choices you make and
tailor our website to provide enhanced features and content to you. For example,
these cookies can be used to remember your username, language choice or country
selection, they can also be used to remember changes you’ve made. The legal
justification of these data processing activities is either performance of contract or
the balancing of interests as there is legitimate interest in providing a better user
experience through an optimized provision of our Services.
o Advertising Cookies: These cookies are used to deliver advertisements that are
more relevant to you and your interests. Please see the section below on “Online
Advertising and Data Collection.”
o Social Media Cookies: In order to enhance your internet experience and to make the
sharing of content easier, some of the pages on our website may contain tools or
applications that are linked to third party social media service providers such as
Facebook, Twitter or Google+. Through these tools or applications, the social media
service provider may set its own cookies on your device. We do not control these
cookies and you should check the social media service provider’s website for further
details about how they use cookies.
• How long will Cookies stay on your browsing device? The length of time a cookie will stay
on your browsing device depends on whether it is a “persistent” or “session” cookie. Session
cookies will only stay on your device until you stop browsing the website that has set the
cookie. Persistent cookies stay on your browsing device after you have finished browsing a
particular website, until they are deleted or until they expire. The maximum duration for
analytics cookies is two years. You can delete the cookies in the security settings of your
browser at any time.
• First and Third-party Cookies: “First party cookies” are cookies that belong to us and that we
place on your device. “Third-party cookies” are cookies that another party places on your
browsing device when you visit our website. Third parties setting cookies from our website
will be providing a service to us or a function of the website, but we do not always control
how third-party cookies are used. Some third parties may use Advertising Cookies to help
gather information about your browsing activity so that they can deliver website advertising
to you that is relevant to your interests. The advertising industries in the EU have developed a
scheme to help you opt-out of receiving cookies used for these purposes. You can find out
more about the EU scheme from www.youronlinechoices.eu. You should check the third
party’s website for more information about how they use cookies.
• Mobile devices: If you enter our website via mobile device with activated location-based
services, we may collect information about your current location as well as the kind of
mobile device in use. Most of the mobile devices provide the possibility to disconnect from
location-based services or to deactivate those.
• How can you manage Cookies from your side? If you would prefer not to accept cookies,
most browsers will allow you to: (i) change your browser settings to notify you when you
receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing
cookies; or (iii) set your browser to automatically reject cookies. Depending on your mobile
device and operating system, you may not be able to delete or block all cookies. Please note
that doing so may negatively impact your experience using the Services, as some features
and services on our Services may not work properly. Depending on your mobile device and
operation system, you may not be able to delete or block all cookies. You may also set your
email options to prevent the automatic downloading of images that may contain
technologies that would allow us to know whether you have accessed our email and
performed certain functions with it. You can find out more information about how to change
your browser cookie settings at www.allaboutcookies.org.
Online Advertising and Data Collection
• Interest-Based Advertising. We participate in interest-based advertising and permit thirdparty
online advertising networks, social media companies, and other third-party services,
such as Google Analytics to collect information about your use of our online services over
time so that they may play or display personalized or interest-based ads on our online
services, on other devices you may use, and on other websites, apps, or services, including
on Facebook. Typically, though not always, the information we use for interest-based
advertising is collected through cookies or similar tracking technologies, which recognize
the device you are using and collect information, including click stream information, browser
type, time and date you visited the site, whether you log in to your account on our Services, or
otherwise engage with us. We and our third-party partners use this information to make the
advertisements you see online more relevant to your interests, as well as to provide
advertising-related services such as reporting, attribution, analytics, and market research.
• We use Google Analytics to help us measure traffic and usage trends regarding the
application webpages and to understand more about the demographics of our users. On our
behalf, Google will use this information to evaluate your use of the website, to compile
reports on website activity and to provide other services relating to website activity and
internet usage to us.
Your Choices
• Interest-based advertising. To learn about interest-based advertising and how you may be
able to opt-out of some of this advertising, you may wish to visit the Network Advertising
Initiative’s online resources at http://www.networkadvertising.org/choices and/or the DAA’s
resources at www.aboutads.info/choices. You may also manage certain advertising cookies
by visiting the EU-based Your Online Choices at http://www.youronlinechoices.eu.
For California residents: By visiting www.privacyrights.info or optout.privacyrights.info/?c=1,
you can opt out from sales of this type of personal information by businesses that
participate in the DAA’s CCPA App-based Opt-Out Tool.
• Mobile advertising. You may also be able to limit interest-based advertising through the
settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest
based ads” (Android). You may also be able to opt-out of some – but not all interest – based
ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and
downloading the mobile AppChoices app.
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If
you delete cookies, change your browser settings, switch browsers or computers, or use
another operating system, you will need to opt-out again.
• Effect of opting out. Please note that when you opt-out of receiving interest-based
advertisements using the mechanisms in this section and the “Online Advertising and Data
Collection” section, this does not mean you will no longer see advertisements from us or on
our online services. It means that the online ads that you do see from DAA program
participants should not be based on your interests. We are not responsible for the
effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the
accuracy of their statements regarding their programs. In addition, third parties may still use
cookies to collect information about your use of our online services, including for analytics
and fraud prevention as well as any other purpose permitted under the DAA’s Principles.
• California Privacy Disclosures:
The California Consumer Privacy Act of 2018 (“CCPA”) requires businesses like ours to
provide certain information. We fully describe our practices to all our members and visitors
in this Privacy Policy but use this separate section to ensure that we meet the CCPA’s
requirements. This California Privacy Disclosures section (the “CA Disclosures”) applies
solely to individual residents of the State of California in the United States. Unless otherwise
expressly stated, all terms in these CA Disclosures have the same meaning as defined in this
Privacy Policy or as otherwise defined in the CCPA.
When we use the term “personal information” in these CA Disclosures, we mean information
that identifies, relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of these CA Disclosures, personal information does not include information
that is publicly available, that is deidentified or aggregated such that it is not capable of
being associated with us, or that is excluded from the CCPA’s scope, such as personal
information covered by certain sector-specific privacy laws, such as the HIPAA, the FCRA,
GLBA or the Driver’s Privacy Protection Act of 1994, or information relating to our job
applicants, employees, contractors and other personnel.
Children’s Privacy
Our Site is not directed to individuals under the age of 16, and we do not knowingly collect personal
information from children. If you believe we have inadvertently collected personal information from a
child, please contact us immediately, and we will take steps to remove the information promptly.
Changes to this Policy
We reserve the right to modify this Policy at any time. Any changes will be effective immediately
upon posting of the revised Policy on our Site. Your continued use of our Site following the posting
of changes constitutes your acceptance of such changes.
Contact Us
If you have any questions, concerns, or requests regarding this Policy or our privacy practices, please
contact us at:
Concentric Technology Solutions, Inc.
4213 Clay Avenue, Haltom City, TX 76117 USA
[email protected]
Telephone: +1-817-503-8862