Effective date: March 1, 2023
Table of Contents
1. Who’s This Policy For And What Does It Cover?
At CR Seymour, Inc. d/b/a Signature Leaders (“Signature Leaders” or “we”), we take your privacy seriously. This Privacy Policy (“Policy”) applies to users of our “Services” (defined below) and individuals we interact with for marketing or other commercial purposes. It describes how we may collect, use, and share your Personal Information. It also explains related rights and choices you may have.
Our Services include our public website (www.signatureleaders.com), the Signature Collective community platform (www.collective.signatureleaders.com), and any other online service we operate that links or refers to this Policy. By using a Service, you consent to the practices described in this Policy.
You may see other privacy notices when we collect your Personal Information for certain purposes. Those notices supplement this Policy.
This Policy includes certain disclosures specific to residents of California, Virginia, and the European Economic Area, United Kingdom and Switzerland, based on laws applicable in those areas. Those disclosures supplement the rest of this Policy.
2. What is “Personal Information”?
When we say “Personal Information,” we mean information that can reasonably be linked to a particular individual or their household. Generally speaking, your Personal Information includes your unique identifiers (full name, phone number, email address, user name, etc.), and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you.
“Non-Personal Information,” on the other hand, has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to a particular individual or their household.
3. Personal Information We Collect And How We Collect It
Personal Information may be collected from you directly, automatically from your device or browser when you use the Service, or from third party sources. The rest of this section describes the categories of Personal Information we collect and provides more detail on when and how they’re collected.
Categories
The Personal Information we collect about you often depends on the nature of your interactions with us or our Services, but may include:
- Identifiers, including your contact information (such as first and last name, address, email address, phone number) and other identifiers that are specific to you or the device or browser with which you access our Service (such as username, signature, IP address, cookie ID and similar information).
- Demographic Information, such as your age, if you choose to provide it. Demographic information may include characteristics of legally protected classifications.
- Financial Information, such as payment card information, which is processed on our behalf by a trusted vendor.
- Commercial Information, including information about what products or services you purchase, obtain or consider when you use our Services
- Professional or Employment Information, such as job title and agency, business or employer name.
- Internet or Network Activity, such as information you share with us via email, information about how you use the Service, social media content you share, interactions with our Service such as the pages that you visit and your preferences, interactions with communications sent on our behalf, and the type of browser or device used to access our Service.
- Audio, Visual, or Electronic Information, including photos, video or other electronic data you choose to upload or share to our Service, customer service audio, or security video recordings
- Geolocation Data, such as your approximate location when you access our Service
- Profile Information, which includes inferences we draw from other Personal Information reflecting your preferences, characteristics or behavior
- Other categories disclosed to you at the point of collection, or that you choose to provide to use either online, over the phone, or offline (such as information about family, life milestones, hobbies and interests)
On Our Public Website
When you visit our public website, you are not required to provide any Personal Information. You may choose to provide us with Identifiers (name, title, email address, and phone number), by filling out a form in our site, in order to receive more information about us or our Services.
Like most online services, our site automatically logs or collects some information from users’ devices in order to provide security, make features function correctly, customize the user experience, understand how the Service is being used, or measure the effectiveness of marketing efforts. Some of this data may be collected through the use of browser cookies or other online tracking technologies, which are explained below. In some cases, we limit this type of collection to Non-Personal Information. However, this data may include Personal Information such as Identifiers, Internet or Other Network Activity and Geolocation Data.
On The Signature Collective Platform
Our Signature Collective Platform is restricted to registered members. When you register an account, we collect Identifiers such as your name and email address. The platform also stores your posts, photos, approximate location or other user content that you generate or upload, and makes that content accessible to other members.
We automatically log some of your Internet or Network Activity on the platform, such as changes you make to your profile, your interactions with on-demand videos, posts or other content, events you register for, and what groups you sign up for. Cookies and other technologies are used on the platform to remember your preferences and collect usage information to improve platform features.
Other Interactions With You
We may collect Identifiers or other Personal Information when you call or emails us, when you visit one of our offices, or when you interact with our representative at a meeting or conference.
4. How We Use Personal Information
We use Personal Information for the following purposes:
- To open and maintain your platform account
- To present, maintain and improve our Services and analyze how they are used;
- To secure our Services against fraud, malicious activity, or conduct that may violate our terms of use;
- To personalize and improve your experience with the Service;
- To provide you with information, products, or services that you request from us;
- To notify you about changes to our Services and any products or services we offer or provide through them;
- To allow you to participate in interactive features on the Service;
- To provide you with periodic product newsletters and offers;
- To contact you and provide you with help if you have a customer service issue;
- To contact you to fill out surveys and participate in other types of market research;
- To conduct marketing and measure performance of our marketing efforts;
- To notify you of new products or services we think you might be interested in;
- To comply with our legal obligations
- To secure our offices and other physical locations
- In any other way we may describe when we collect the information; and
- For any other purpose with your consent.
We may use Non-Personal Information for any purpose.
5. How We Share Personal Information
Through Our Platform
Other platform members will be able to see your profile on the platform unless you choose to hide your profile in account settings. Content and information you post to the platform will be shared with other members as well, consistent with the platform’s purpose of networking and community building.
Vendors
We may share Personal Information with contractors, service providers, and other vendors who assist or support us in providing the Services. Examples of these third party services may include hosting our website or platform, storing data, performing analytics, processing payments, or sending marketing communications. Our agreements with vendors typically prohibit them from retaining, using or disclosing the Personal Information we share with them for any purpose other than providing services to us.
Analytics or Marketing Partners
We may share your Personal Information with analytics providers or marketing partners to measure performance of our Service or conducting marketing. This sharing may involve the use of browser cookies and similar technologies placed through our Service by our partners, as explained here. For example, when you visit our website, our partner’s Cookie may cause your browser to automatically send a request to our partner’s server and provide our partner with your IP address, other Identifiers, and Internet or Other Network Activity. (Some partners may have an agreement with us that qualifies them as our restricted service provider.)
Mandatory Disclosures And Legal Proceedings
We may have a legal obligation to disclose Personal Information to government authorities or other third parties pursuant to a valid request, subpoena or court order. We may also need to disclose your Personal Information in accordance with applicable law to prevent physical harm or financial loss, protect the vital interests of a person, enforce our various policies or terms of use, protect our property, services and legal rights, prevent fraud, support auditing, compliance and corporate governance functions, or comply with applicable law.
Change In Control Or Merger
We may transfer your information in the event of the sale of substantially all of the assets of our business to a third-party or in the event of a corporate merger, consolidation, acquisition or reorganization. However, in such event, any acquirer will be subject to the provisions of our commitments to you or we will not disclose your information.
With Your Direction Or Consent
We will share your Personal Information with other third parties as you may direct or otherwise consent.
6. Children’s Privacy
Our Services are not directed to children (individuals under the age of 18). We do not knowingly collect, maintain, or process children’s Personal Information unless the child’s parent or guardian consents and provides the information. If we determine that we have received a child’s Personal Information from a source other than the child’s consenting parent/guardian, we will delete the information.
7. Cookies And Online Tracking
What Are Cookies?
A browser cookie is a small piece of data that a website stores in your device’s browser. It holds information that the site uses to function properly, remember your preferences, or personalize your experience. A typical cookie contains a cookie ID, which is a unique string of characters used to identify your browser during the browsing session, or in some cases, during subsequent browsing sessions. Cookies, cookie ID’s and similar pieces of data may be considered Personal Information (identifiers or internet activity) under applicable law.
Other online technologies, similar to cookies, may allow users to be identified and tracked across multiple browsing sessions, and in some cases tracked across different websites and online services for marketing or advertising purposes. These technologies include, but are not necessarily limited to, pixels, web beacons and scripts (collectively with browser cookies, “Cookies”).
How Cookies May Be Used On Our Services
Our Service uses “first party” Cookies, which are set by us. Our Service also uses some “third party” Cookies, which are set by our vendors or partners. This means that, when you visit our site, your browser may automatically connect to our vendor or partner’s online server, as well as ours, and provide them with access to your online identifiers and information about how you use our site.
Both First Party and Third Party Cookies may be used on our Services for the following purposes:
- Essential/Necessary: Essential Cookies are necessary for site security and core functionality.
- Functional. Functional Cookies enable enhanced functionality, like managing support and contact requests.
- Experience. Experience Cookies enable additional features to enrich your experience, like social media features.
- Measurement: Measurement Cookies allow us to analyze use of our Service to evaluate and improve performance.
- Marketing: Marketing Cookies are used by advertisers to serve ads that are more relevant to your interests on our Service or other sites you visit.
For more details, and for a list of the vendors and partners who place Cookies through our Services, click here.
How You Can Block Cookies
To change your cookie preferences for our site, click the “Your Privacy Choices” or “Cookies” link at the bottom of our homepage.
You can block, disable or delete cookies at any time by changing the settings in your browser. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages of our site or other sites. You can find more information about cookies and other options you may have for restricting them at www.cookiesandyou.com/, and www.aboutads.info/choices.
“Do Not Track”
You browser may include a “Do Not Track” (DNT) setting. We do not currently honor DNT signals because there is not an industry consensus on what such signals mean.
8. Your Rights And Choices
If you have an account with us, you can delete or change your information in your account settings.
You may opt-out of our marketing emails by using the unsubscribe link provided in the email.
See Section 7 for options to restrict Cookies.
If you reside in California or Virginia, or in the European Economic Area, United Kingdom or Switzerland, you may have additional rights and choices.
9. Links To Third Party Sites
Our Services may contain links to third-party websites, products or services. If you use these links, you will leave our site. Such links do not constitute or imply an endorsement, sponsorship or recommendation by us of the third party, the third-party website or the information contained therein, and we shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.
10. Third Party Direct Marketing
We don’t share Personal Information with third parties for their direct marketing purposes.
11. Security & Retention
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.
Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Please note that in many situations we must retain all, or a portion, of your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, to protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.
12. California Residents (CCPA Statement)
This statement makes additional disclosures to California residents (i.e., “consumers”), and describes rights they have, under the California Consumer Privacy Act of 2018, as amended.(the “CCPA”). You can learn more about the CCPA here: https://oag.ca.gov/privacy/ccpa
Collection Of Personal Information
The categories of Personal Information we have collected about consumers in the past 12 months include the categories listed in Section 3 of our Privacy Policy
Sale, Sharing Or Disclosure Of Personal Information
Under the CCPA, you may request to opt-out of the “Sale” of your Personal Information—which the CCPA defines very broadly to include some transactions or arrangements that do not involve the exchange of data for money—and the “Sharing” of your personal information, which the CCPA defines as sharing with third parties for purposes of cross-site targeted advertising. The use of third party analytics or advertising cookies may be considered a Sale or Sharing of website visitors’ Personal Information under the CCPA. As a result, within the past 12 months, we may have Sold or Shared the following categories of Personal Information (to the categories of recipients listed) by using such cookies on our site:
- Identifiers (to analytics or marketing partners)
- Internet or Network Activity (to analytics or marketing partners)
To request that we stop Selling or Sharing your Personal Information, click the “Your Privacy Choices” link at the bottom of our website’s homepage.
We do not knowingly Sell or Share the Personal Information of consumers under 16 years of age.
Within the past 12 months, we disclosed the following categories of Personal Information for a business purpose (to the categories of recipients listed):
- Identifiers (to vendors)
- Financial Information (to vendors)
- Commercial Information (to vendors)
- Internet or Network Activity (to vendors)
Your Rights As a Californian
California residents have the right to make the following requests to covered businesses. The requests may be made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a person authorized by the consumer to act on the consumer’s behalf.
Right To Request Information About Collection, Disclosure, Sale or Sharing
You have the right to request that a business disclose to you: (i) the categories and specific pieces of Personal Information the business has collected about you within the past 12 months, (ii) the categories of sources from which the Personal Information is collected, (iii) the business or commercial purposes for collecting, Selling or Sharing Personal Information, and (iv) the categories of third parties to whom the business discloses Personal Information.
If a business Sells or Shares Personal Information, or discloses it for a business purpose, you also have the right to request that the business disclose the following with respect to the 12-month period preceding your request: (i) the categories of Personal Information that the business Sold or Shared about you and the categories of third parties to whom the Personal Information was Sold or Shared, and (ii) the categories of Personal Information that the business disclosed about you for a business purpose.
This type of request may be referred to as a “Request to Know.” Before we can honor a Request to Know, we need to verify that the person making it is the consumer whose Personal Information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized disclosure.
Right to Request Deletion
You have the right to request that a business delete any Personal Information that the business has collected from you. This type of request may be referred to as a “Request to Delete.”
Before we can honor a Request to Delete, we need to verify that the person making the request is the consumer whose Personal Information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized deletion.
We are not required to delete Personal Information if we still need it in order to complete the transaction for which the information was collected, perform a contract with you, comply with a legal obligation, or accomplish any other objective recognized as an exception to the right to deletion under applicable law.
Right to Request Correction
You have the right to request that we correct inaccurate Personal Information about you. This type of request may be referred to as a “Request to Correct.” By visiting your account settings, you can correct and change certain Personal Information associated with your account.
Right to Opt-Out of Sale or Sharing
You have the right to direct a business that Sells or Shares Personal Information about you to third parties not to Sell or Share your Personal Information. This type of request may be referred to as a “Request to Opt-Out.”
Right to Limit Use and Disclosure of Sensitive Personal Information
If a business collects Sensitive Personal Information* for the purpose of inferring characteristics about you, you have the right to request that the business limit its use and disclosure of your Sensitive Personal Information to that use and disclosure which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods and services. (Signature Leaders does not collect Sensitive Personal Information for the purpose of inferring characteristics about you.)
*Sensitive Personal Information includes social security number; driver’s license or state identification number; complete account log-in credentials; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email and text messages (unless the business is the intended recipient of the communication); genetic data; biometric information; health information; and information concerning sex life or sexual orientation.
Right to Non-Discrimination
You have the right not to receive discriminatory treatment by a business for the exercise of your privacy rights under the CCPA.
How to Submit a Request To Know, Delete or Correct
You can submit a Request to Know, Delete or Correct to privacy@signatureleaders.com. The request must state “CCPA Request” and include:
- your first and last name;
- an email address at which you can be reached for purposes of the request;
- the California county in which you reside;
- for a Request to Know, the disclosure(s) you are requesting;
- for a Request to Delete, a clear statement that you want us to delete your Personal Information; and
- the reason(s) you believe we have collected, disclosed, Sold or Shared your Personal Information, specifically, within the past 12 months (for example, you registered an account on our platform or received a communication from us)
If you are submitting a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and provide proof of permission from the consumer to make the request.
After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.
How to Submit a Request to Opt-Out
To request to opt-out of the Sale or Sharing of your Personal Information, click the “Your Privacy Choices” link at the bottom of our website’s homepage.
13. Virginia Residents
Your Rights Under The VCDPA
Virginia residents who interact with a business in a consumer context (as opposed to a business-to-business or employment context) have certain rights under Virginia’s Consumer Data Protection Act (“CDPA”), including:
- To confirm whether or not a business is processing the consumer’s Personal Information and to access such Personal Information;
- To correct inaccuracies in the consumer’s Personal Information;
- To delete Personal Information provided by or obtained about the consumer;
- To obtain a copy of the consumer’s Personal Information that the consumer previously provided to the business in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another business without hindrance (if the data is processed by automated means)
- To opt out of the processing Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling in furtherance of decisions that produce legally or similarly significant effects concerning the consumer.
How To Exercise Your Rights Or Appeal A Decision
To exercise one or more rights under VCDPA, please submit a request to privacy@signatureleaders.com. The request must state “Virginia Privacy Request” and include:
- your first and last name;
- an email address at which you can be reached for purposes of the request;
- the Virginia county in which you reside; and
- A description of the VCDPA rights you are exercising.
- The reason(s) you believe Signature Leaders has obtained your Personal Information
After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.
If we decline to act on your request, you have a right to appeal. To submit an appeal, please contact us at privacy@signatureleaders.com.
How To Opt-Out Of Targeted Ads On Our Services
To opt-out of targeted advertising on our Services, please click the “Your Privacy Choices” link at the bottom of our homepage.
The VCDPA defines a “sale” of Personal Information as the exchange of Personal Information for monetary consideration. Signature Leaders does not exchange Personal Information for monetary consideration
14. Data Subjects In The EEA, United Kingdom and Switzerland
Data controller
Your Personal Information is controlled by CR Seymour, Inc. d/b/a Signature Leaders, a company that is incorporated in the State of Georgia, U.S.A., and maintains its headquarters in Atlanta, Georgia, U.S.A. Signature Leaders does not maintain an office or other establishment outside of the United States. You may contact Signature Leaders here.
Lawful bases for processing
We may process your Personal Information for the purposes described above if at least one of the following grounds for processing applies:
- Processing is necessary for us to perform a contract with you or to take steps at your request prior to entering into a contract;
- Processing is necessary to comply with our legal obligations;
- Processing fulfills our legitimate interests in a manner that does not outweigh your rights and freedoms. Our legitimate interests include: protecting against malicious intrusions and unauthorized use; maintaining and improving our Site and Portal; understanding how our services are used; personalizing our services; promoting our products and services effectively; and complying with legal obligations and protecting our legal rights.
- Processing is necessary to protect the vital interests of you or another individual
- You have consented to the processing
International transfers
If you use a Service or contact us, your Personal Information will be processed in the United States—which has not received a finding of “adequacy” as referenced in Article 25 of the European Union’s or UK’s General Data Protection Regulation (GDPR)—and will be handled in accordance with this Policy and applicable U.S. law, unless we have agreed otherwise in writing with you or a third party you are affiliated with.
To the extent we make transfers of Personal Information to third parties in other countries that have not received an adequacy finding, we rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we make such transfers: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. We also endeavor to enter into data processing agreements and European Commission-approved model clauses with service providers whenever necessary and appropriate.
Automated decision making
We do not make any decisions involving the use of algorithms or profiling that significantly affects you.
Your rights under GDPR
The GDPR provides you with the following rights, which you can exercise by contacting us:
- The right to request access to and rectification of your personal information. You may obtain additional information about our processing and a copy of your stored information. You also have the right to request that we update your information if it is inaccurate or incomplete.
- The right to request erasure of your personal information. You may request for us to erase your information from our systems if it is no longer necessary for the reason we collected it, or you withdraw consent and no other legal basis for processing exists.
- The right to restrict our processing of your personal information. You have the right to restrict our processing if: (1) you disagree with the accuracy of your information; (2) our processing is deemed unlawful and you do not want us to erase your information; or (3) we no longer need your information for the purposes for which we collected it but we must store it to comply with our legal obligations.
- The right to data portability. You may receive and transmit your personal information to another controller where our processing is based on consent you gave us and was carried out by automated means.
- The right to object. You have the right to object to our processing of your personal information where we process it because of a legitimate interest.
You also have the right to file a complaint with the supervisory authority of your member state or country.
15. Changes To This Policy
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.
16. Contact Us
If you have any questions or concerns about this Policy, please contact us via privacy@signatureleaders.com.
Carol Seymour