Privacy Policy

CT NASSAU (Continental Ticking Corporation of America)

Data Controller

CT Nassau – Continental Ticking Corporation of America (hereinafter “CT” or “Controller” or “we”), tax ID: (EIN): 561917006 with headquartered at 4101 South NC Hwy 62, Alamance, NORTH CAROLINA 27201-0039 – PO BOX 39, is the data controller for the processing of users’ personal data collected through the website www.ctnassau.com (“Website”) and on its social network pages. The data will be processed in compliance with current United States legislation and as indicated below.

This Privacy Policy explains what personal information we may collect, when we may collect it, how we may use it, with whom we may disclose it, and certain jurisdiction-specific rights.

This information applies exclusively to the processing of personal data carried out through the Website; any third-party websites which are accessible through links, banners or hypertext links are governed by the privacy policy of their respective operators. Users are therefore invited to also read those policies.

CT operates on the Website, of which it is the owner, as a provider of services deriving from registration on the Website, also for generic marketing purposes, as set out below.

 

Contact details of the Data Controller

CT takes the utmost account of the right to privacy and protection of the personal data of its Users. For any information or request relating to this Privacy Privacy, to the processing of their personal data and/or to the exercise of their rights, Users can write to the following addresses:

  • e-mail: privacy@ctnassau.com
  • postal address: 4101 South NC Hwy 62, Alamance, NORTH CAROLINA 27201-0039 – PO BOX 39

 

Type of personal data

Please note that the Website and the related services are reserved for individuals who have reached the age of sixteen. CT does not collect personal data relating to persons under the age of 18 (eighteen). At the request of the Users, CT will promptly erase all personal data involuntarily collected that relates to persons under the age of 18 (eighteen).

CT collects and processes the following types of data from Users who access and/or register on the Website:

3.1) Personal data collected automatically 

Browsing data: during their operation, the computer systems and software used for the functioning of the Website will acquire certain types of personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected with the purpose of identifying the data subjects, but due to its nature it could lead to user identification through processing operations or association with data held by third parties. This category of data includes, for example, the IP addresses or domain names of the computers operated by the Users connected to the site, as well as other parameters relating to the User’s operating system and IT environment.

Aggregated information about user behaviour on the Website (such as clicks and/or mouse movements) collected through the use of cookies; for more information on the use of cookies by CT, the user is invited to read the Cookie Policy published on the Website.

3.2) Personal data provided directly by the user 

  • • Personal and identification data (for example name and surname); contact details and addresses (such as e-mail address, postal address, telephone number, mobile number); account password (in case of registration) and other details provided during registration on the Website or while using the Services on the Website.
  • • Any contacts with CT made through the FAQ service present on the Website or the optional and spontaneous sending of messages by e-mail or traditional mail, to the addresses of CT indicated on the Website, will entail the subsequent acquisition of the address or e-mail of the sender or of their telephone number in order to respond to requests, and of any other personal data included in the communications;
  • • Data relating to the User’s shopping habits and preferences;
  • • Any data of third parties, which may still be acquired by CT due to being entered by the User for various reasons, even if the third parties do not use the Website Services. If third-party data is provided, the User is required to guarantee to CT that they have expressly obtained the third party’s prior consent and that they will provide the information contained in this policy. The User is required to make sure that the personal data provided to CT are correct and, in the event of changes, update the data by writing to CT or by using the options allowed within the User’s personal area, if the User is registered.
  • • Personal data collected through social media pages used by CT.

 

CT may also collect certain personal data of the User when interacting on active social network pages. Certain information will be communicated to CT directly by the User when they decide to share images published on CT’s social media pages through their profile, comment on posts and/or “like” a product, initiative or event published by CT by selecting the appropriate forms, or when they decide to send CT a message via private chat or other social media channels.

CT may also receive certain information indirectly due to the User’s interaction with CT ‘s own social media pages.

The knowledge of the User’s personal information may depend on the User’s social network settings and the content they have chosen to make public. Such information may also

include the name, surname, certain contact details and the image on the User’s social profile. We remind you that certain details will be visible to CT if the User decides to follow CT’s social media pages; for this reason, the User is invited to read the privacy information of the various social networks and to check their privacy settings.

 

Methods and purposes of data processing by CT Nassau

Although data processing in print is not excluded, your personal data will mainly be collected and processed electronically, also with the aid of electronic and online methods, according to the principles of necessity, lawfulness, correctness, proportionality and transparency, for the purposes and according to the conditions of lawfulness (the legal basis) indicated in the relevant section.

CT will process the User’s personal data in order to allow:

  • browsing on its Website;
  • registration on the Website and provision of the related services;
  • the fulfilment of requests sent by the User (eg in relation to assistance and/or requests for information or contact on the Website);
  • the receipt of and replies to requests to exercise the rights of the data and to perform all the consequential activities;
  • to execute obligations, or to fulfil obligations imposed by law, by an Authority or by the applicable legislation;
  • the User’s interaction with social media pages, the sending of comments, the sharing of posts and reviews on the Website etc.;
  • the verification, exercise or defence of a right before all the competent authorities;
  • verification of the User’s identity thus avoiding possible abuses or fraud;
  • prevention of improper use of the Website or of the related services or connected social media pages, and the prevention of computer crimes (eg attempted fraud);
  • with prior express consent, the sending of commercial, advertising and promotional communications, the sending of newsletters, discount coupons and special offers for products and/or services advertised on the Website and the carrying out of market research by e-mail, post and/or telephone contact (calls or texts) known as “generic marketing”);
  • with express consent, the monitoring and tracking of user behaviour on the Website, the collection and logging of browsing data (eg: pages visited, categories of products viewed.

Without prejudice to any other provisions of the Privacy Policy, under no circumstances will CT make the Users’ personal data available to other Users and/or to third parties.

 

Legal basis of the data processing, granting of consent and revocation, conservation of data

The legal basis for the processing of data varies according to the purposes related to the processing of the data.

The legal basis may be the execution of measures adopted at the request of the data subject (eg registration on the Website), legitimate interest (eg the exercise or defence of a right) or

the express consent of the User (eg the sending of newsletters and/or promotional communications, known as “generic marketing”).

The provision of data for the purpose of generic marketing and profiling is optional: there is no legal or contractual obligation for the User to provide such data for this purpose and/or to give consent to the processing of their personal data for this purpose. Non-provision of consent does not affect the browsing or use of the Website in any way.

The processing of data for this purpose may be fully automated without any human intervention, using an algorithm with pre-set parameters.

A decision based solely on automated processing, including profiling, produces legal effects that relate to the data subject as it is necessary for the fulfilment of the contract between the data controller and the data subject and/or is in any case connected to such contract and its validity and efficacy.

The User therefore has the right, at any time, to:

– obtain human intervention by CT;

– express their opinion;

– contest the decision taken by CT.

To exercise this right, the User can contact CT at the addresses indicated in point 2) of this Policy.

You can object at any time to the sending of further promotional communications by sending an e-mail to the above addresses. The User can also revoke the consent given in the same way at any time and / or oppose, at any time, the processing of his data for profiling purposes for marketing purposes.

Once the consent has been revoked, CT will send an e-mail to confirm.

Following the exercise of the right to object to the sending of promotional communications, it is possible that, for technical and operational reasons, some further promotional communications may still be received. If this does occur after 24 hours have elapsed from the exercise of the right of objection, the User is requested to report the problem to CT using the contact details indicated in point 2) above.

If the User does not give consent to the processing of their data for using or registering on the Website, it will not be possible for that User to browse on or register on the Website nor use the services offered by CT.

Without prejudice to the warnings indicated above, the User may at any time revoke the consent given and/or object to the processing of their data, also for reasons connected to their personal situation.

To exercise this right, the User can contact CT at the addresses indicated in point 2) above.

CT will keep and process the User’s personal data for the time strictly necessary to carry out the individual processing activities which may vary according to the purposes indicated above, in compliance with the statutory conservation obligations and the limits established by law (eg in cases where the User has an account, until that account has been closed).

In the event of a dispute with the User, the personal data may be kept for the time reasonably necessary to complete such purposes and/or for the time during which claims may be pursued.

For generic marketing and profiling purposes, CT will process the User’s data until the consent is revoked and/or the right to object is exercised and, in any case, not beyond the limits of the law.

 

Communication of the User’s personal data

CT may disclose the personal data provided by the User, to third parties including: legal, tax or administrative consultancy firms, suppliers of goods or assistance centres, third-party companies such as technology or IT service providers or logistics providers whose services are functional to the operation of the Website, suppliers of outsourced or cloud computing services (e.g. for sending newsletters, promotions, data analysis and processing etc.), public or competent authorities (e.g. in the event of a dispute or commission of crimes) etc. Persons acting as independent data controllers will only have access to the data necessary to provide their services and are not authorised to retain Users’ data for other purposes.

If the User interacts with social media pages, their data may be known by the companies that manage the social networks as independent data controllers.

The personal data provided by the User may also be communicated by CT to its employees and/or contractors in charge of managing the Website and/or the related services.

Such persons – who are formally appointed by CT as “Data Processors” or “Authorised Processors” under the direct authority of CT, will process the User’s data exclusively for the purposes indicated in this Privacy Policy and in compliance with the applicable provisions of law.

The User’s personal data will not be disclosed or transferred to third parties for use for their own purposes; in the event of any extraordinary corporate transactions (e.g. the sale or lease of a company, merger etc.), the data may be transferred or given to third-party buyers, tenants or other authorised persons.

 

Transfer to third countries and accessing CT site globally

In compliance with the conditions and guarantees established by United States law, your data may be transferred to countries not belonging to the United States, which may not offer a level of protection of privacy and personal data protection comparable to the one guaranteed by United States law; CT, as Data Controller, gives the utmost consideration to data security and will thus manage such data transfers with all due caution and guarantees.

By using this site, User understand and accept that its Personal Data will be collected, stored, and processed in the United States and in any country to which CT may transfer its informations. CT may transmit Personal Data about Users to related affiliates worldwide.

These affiliates may in turn transmit Personal Data to other related affiliates. Some affiliates may be in countries that do not ensure an adequate level of data protection. Nevertheless, all related affiliates are required to treat Personal Data in a manner consistent with this notice. To obtain additional information regarding the safeguards we have in place for cross-border transfers of Personal Data, please contact us using the information provided at point 2).

 

Rights of the User

Under the United States law, User has the right to:

1. know how its personal informations are used;

2. access request and receive its personal informations collected;

3. object to having its data sold or shared;

4. request to delete its personal data.

To exercise these rights, the User can contact CT at the addresses indicated in point 2) above.

In the communication, the User must indicate the name, surname, e-mail address, postal address to allow to correctly manage the request.

 

Time of Data collection

With respect to the United States law, CT may retain User’s Data for up to 10 years from the date the personal data has been collected.

When Users purchase products from CT, CT may also retain information about order history (such as Transaction Data relating to previous orders) for up to 10 years.

Legal requirements, however, may require to retain some or all of the personal information CT hold for a period of time that is longer than that for which we might otherwise hold.

When personal information is no longer required by CT or by law, CT will either convert it into an aggregated non-identifying form or CT will appropriately destroy or erase the personal information.

 

Children’s Privacy

CT Nassau online services are not intended for children under the age of 18 (eighteen) and we do not knowingly collect information online from children under the age of 18 (eighteen). If we become aware that we have obtained information from a child under the age of 18 (eighteen) we will delete such information in accordance with applicable law.

 

International

To support CT operations, the majority of our computer systems, networks, and devices are currently based in the United States. Accordingly, personal information we obtain through

our services may be processed in the United States and elsewhere where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By accessing our services, you consent to the collection and processing of your personal information in the United States.

 

Protection

CT protects its Website and/or its other IT systems with adequate technical and organisational measures in order to avoid the loss, destruction, modification or dissemination of the user’s personal data, or access to personal data by unauthorised third parties.

If the User is registered, access to the personal account is only possible after entering the password chosen by the User. CT does not have access to the password because it is stored in an indecipherable encrypted form.

The User is asked not to disclose their access data to third parties, and they should log out of the customer account at the end of a session, especially if their device is shared with other users.

CT declines all liability for any improper use of the password by the User.

 

Updates and changes

This Privacy Policy may be updated over time, also in consideration of any changes to United States laws regarding the protection of personal data. The changes and updates will apply from the time of their publication on the Website (for changes for which the law requires consent to be given, the User will be able to make a free choice). Users are invited to periodically consult the relevant section of the Website, for any updates.

CT reserves the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use indicates your consent to the Privacy Policy posted at the time of use. To the extent any provision of this Privacy Policy is found by a competent court to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

 

Contact

To change selections about receiving promotional communications, or to update Users personal information, can contact CT by email, telephone, or postal mail. It may take up to 10 days to process your email request and 6-8 weeks to process your postal mail request, during which period you may continue to receive communications from CT. In certain countries, we may be subject to shorter time periods for certain types of request as a matter of law.

  • e-mail: privacy@ctnassau.com
  • postal address: 4101 South NC Hwy 62, Alamance, NORTH CAROLINA 27201-0039 – PO BOX 39
  • Phone +1 336-570-0091

SECTION B – California Privacy Policy

California residents have certain privacy rights detailed aboveTo the extent that there is a conflict between this Privacy Policy and the California Consumer Privacy section, the California Consumer Privacy section will control.

California Consumer Privacy Act (“CCPA”) 

This section only applies to individual residents of California. The California Consumer Privacy Act (“CCPA”) gives California residents certain rights. This section covers our Collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA.

Capitalized terms defined in the CCPA that are used in this section shall have the same meaning as in the CCPA.

Collection, Use and Disclosure of Personal Information 

Generally, we Collect, retain, use, and disclose your PI to provide you the CT Services and as otherwise related to the operation of our business. In addition, we may Collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this section.

Information We Collect and Disclose 

During the 12-month period prior to the effective date of this Privacy Policy, we may have Collected the categories of personal information about you, and disclosed them to the following categories of third parties.

Identifiers: such as name, nickname, alias, contact information including email, phone number, and address, User ID, password, IP address, device ID, and account name and number o Business Purpose Disclosures: Service Providers, such as cloud vendors, analytics companies, social media networks, and advertising providers

  • Personal Records: such as financial account information o Business Purpose Disclosures: Service Providers, such as cloud vendors and financial services companies
  • Personal Characteristics and Traits: such as age and gender o Business Purpose Disclosures: Service Providers such as cloud vendors, analytics companies, advertising providers, and social media networks
  • Customer Account Details / Commercial Information: such as purchase or service history o Business Purpose Disclosures: Service Providers such as analytics companies, advertising providers, cloud vendors, financial services companies, and social media networks
  • Internet Usage Information: such as browsing history, referring URLs, search history, interactions with advertising links, and CT mobile application usage o Business Purpose Disclosures: Service Providers such as cloud providers, analytics companies, advertising providers, and social media networks
  • Geolocation Data: such as your location we infer based on your IP address o Business Purpose Disclosures: Service Providers such as analytics companies, advertising providers, and social media networks
  • Sensory Data: such as voice recordings from call centers o Business Purpose Disclosures: Service Providers such as customer service providers
  • Inferences from PI Collected: such as customer profiles, including customer characteristics and behaviors o Business Purpose Disclosures: Service Providers such as analytics companies, advertising providers, and social media networks

In addition to the disclosures described above, we may disclose each category of personal information above with independent CT dealerships, or our other affiliates at your request or to enable us and our affiliates to provide goods or services to you. Upon request and as required by law, we may provide identifiers, personal records, personal characteristics and traits, customer account details and commercial information, internet usage information, geolocation data, sensory data, and inferences from PI with government entities, including law enforcement.

We Collect the categories of PI above directly from you, your device or browser, Service Providers that assist us in providing the CT Services and running our internal business operations, public databases, social media networks, and data providers. We Collect, use and disclose the PI we Collect for the Business Purposes in the bulleted list below and for the purposes described in this Privacy Policy (collectively, our “Business Purposes”).

  • Providing the CT Services and our products, including maintaining and servicing your account, verifying your information, processing payments, advertising or analytics services, and similar functions and services
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity
  • Debugging the CT Services to identify and repair errors
  • Internal research and development
  • Quality and safety assurance, and improving, upgrading, and enhancing our products and Services
  • Processing and managing interactions and transactions on the CT Services

We may also disclose your PI for additional Business Purposes, as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, to the Consumer or other parties at the Consumer’s request, for the additional purposes explained in this Privacy Policy, and to assignees as part of a merger or asset sale.

User’s CCPA Rights 

Right to Opt-Out of Sale of Personal Information 

We do not knowingly Sell your PI. For this reason, we do not treat PI Collected by us as subject to a Do Not Sell request and, therefore, we do not offer a way for you to submit such a request. There is not yet an industry consensus as to whether third-party cookies and tracking devices associated with our websites and mobile apps may constitute a “Sale” of

your PI as defined by the CCPA and as such, we do not treat such information as subject to a Do Not Sell request.

However, third parties may Collect Personal Information through the CT Services for advertising, analytics and other purposes. Please visit Privacy Rights Info to opt-out of what these participating third parties consider a Sale of PI. This is a third-party program and we are not responsible for its effectiveness. You must opt out on every device and browser you use in order to effectuate your “Do Not Sell” requests from these parties. However, opting out does not mean you will stop seeing ads and you may still continue to see interest-based ads.

You can exercise control over browser-based cookies by adjusting the settings on your browser. For additional details about your choices regarding certain kinds of online interest-based advertising, visit our Cookie Policy (LINK).

We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to disclose PI; (ii) to comply with your requests under the CCPA; (iii) disclosures among the entities that constitute CT NASSAU, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.

California Minors 

We do not knowingly Sell the PI of Consumers under 18 (eighteen). Any California residents under the age of 18 (eighteen) who have registered to use the CT Services, and who posted content or information on the CT Services, can request removal by contacting us at Data Privacy@stellinigroup.com detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.

Rights to Know and Delete Personal Information 

California Consumers have the right to exercise certain privacy rights under the CCPA. California Consumers may also exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we Collected PI.

If you are unable to provide us with certain information about yourself and your interactions with CT NASSAU we will be unable to verify your identity to fulfill a request to know or delete. In some cases, we may verify your identity by confirming that you are the owner of the email address we have on file. For your specific pieces of information, as required by the CCPA, we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above.

Some PI we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s PI (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that Personal

Information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Consumer PI that we Collect, Process, store, disclose, and otherwise use and to respond to your California Consumer rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

You may use an authorized agent to submit a Consumer rights request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.

a. Categories of PI 

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

  • The categories of PI we have Collected about you;
  • The categories of sources from which we Collected your PI;
  • The business or commercial purposes for our Collecting or Selling your PI;
  • The categories of third parties to whom we have disclosed your PI;
  • A list of the categories of PI disclosed for a Business Purpose in the prior 12 months, or that no disclosure occurred.
  • A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred. If we Sold your PI, we would explain the categories of your PI we have Sold and the categories of Third Parties to which we Sold PI, by categories of PI Sold for each Third Party.

b. Specific Pieces of PI 

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have Collected, and are maintaining, in the period that is 12 months prior to the request date. Please note that we retain PI for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

c. The Right to Deletion 

You may request that we delete your PI that we have Collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your PI for regulatory reasons, to complete a warranty or other contract with you, or for other internal uses of the information that are compatible with the context in which you provided it. Note also that we are not required to delete your PI that we did not Collect directly from you.

Your Rights 

To exercise the right to know or right to delete, you may submit a request by:

  • e-mail: privacy@ctnassau.com
  • postal address: 4101 South NC Hwy 62, Alamance, NORTH CAROLINA 27201-0039 – PO BOX 39

Please include your name, address, email address, and phone number in your request. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so. We will not discriminate against any consumer for exercising these rights, as described further below.

Notice of Financial Incentive and Non-Discrimination 

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable PI.

Notwithstanding anything to the contrary, we may Collect, use, and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

California Shine the Light Law 

California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of “personal information” (as defined by the “Shine the Light” law) to third parties for their own direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by:

  • e-mail: privacy@ctnassau.com
  • postal address: 4101 South NC Hwy 62, Alamance, NORTH CAROLINA 27201-0039 – PO BOX 39

Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.