Privacy Policy

Types of Information We Collect

Personal Information: "Personal Information" identifies, relates to, or describes a specific individual ("you"), such as your name, job title, or location data. Personal Information also includes information that we can reasonably link to you.

• Identifiers: Include name, postal address, device/network identifiers, IP addresses, emails, and social media accounts. This information may be disclosed and comes directly from you, our business partners, and third parties at your direction.
• Contact Information and Signatures: Covers contact details and information you may share or make public on social networks. Information may be disclosed and comes directly from you, our business partners, and third parties at your direction.
• Protected Classification Characteristics: In accordance with the law, we collect this information to provide our services. Information is disclosed and comes from you and our business partners.
• Commercial Information: Includes transaction history, financial data, and payment information. This information may be disclosed and comes directly from you, our business partners, and third parties at your direction.
• Internet Activity Information: Includes browsing history and interaction with our websites and systems. This information may be disclosed and comes directly from you, our business partners, and third parties at your direction.
• Geolocation Data: Such as device location and IP address. Information may be disclosed and comes from you, our business partners, and third parties at your direction.
• Audio, Electronic, Visual, and Similar Information: For example, call recordings and audio and video recordings of events. Information may be disclosed and comes directly from you and our business partners.
• Professional or Employment-Related Information: Such as employer name and job title. Information may be disclosed and comes directly from you, our business partners/clients, and third parties at your direction.
• Education Information: Such as educational records. Information may be disclosed and comes from you, our business partners/clients, and third parties at your direction.
• Inferences Drawn from Any of the Above Personal Data: For creating a profile or resume, for example, about a specific individual's commercial preferences. Information may be disclosed and comes directly from you, our business partners/clients, and third parties at your direction.

How We Collect Information

Information Provided by You:

This includes information that you voluntarily agree to provide when using our Services. This may include communication with us via email or other channels, subscribing to our newsletter, participating in webinars or events, and responses to our inquiries or communications.

Information Collected Automatically:

We collect data through browser cookies and similar technologies that provide us with certain information when you use, access, or interact with our Services. This may include your device type, operating system, IP address, browser type, pages viewed, and other similar information.

Our website also uses advertising tracking technologies, including the loading of JavaScript code and discreet images, to create your profile for advertising targeting or to identify you on our site. These technologies are often used in addition to cookies to create your profile. Trackers on our site transmit data to online advertising companies, including Facebook (Meta Platforms, Inc.), Alphabet, Inc., Twitter, Inc., and Microsoft Corporation.

Information from Other Sources:

We may receive information about you from other sources, including third parties, that help us update, expand, and analyze our records, as well as identify new customers or prevent or detect fraud.

Use of Data from Forms:

We value the information you provide through forms on our site. These forms may include contact requests, newsletter subscriptions, event registrations, or other inquiries related to our services. When filling out forms on our site, we may collect the following types of information:

• Name
• Email Address
• Phone Number
• Other Contact Information
• Company Name
• Number of Employees in the Company
• Other Company Information

Additionally, when one fills out a form on our site, we automatically receive the following information:

• User's IP Address
• Lead Name (lead_name)
• Website URL
• UTM Tags (utm_source, utm_medium, utm_campaign, utm_term, utm_content), which help us track the effectiveness of our marketing campaigns and traffic sources.

We use this data to process your requests, provide the requested services, improve the quality of our services, and personalize your experience on the site. Your information helps us better respond to your individual needs and preferences.

How We Use Cookies

We use the following types of cookies:

• Persistent Cookies: We use persistent cookies to enhance your experience using the site. This includes recording your consent to use cookies, which first appears when you use the site.
• Session Cookies: Session cookies are temporary and are deleted from your device when your web browser closes. We use session cookies to track internet usage as described above.
• Third-Party Cookies: Our site uses cookies from third parties, including ZOHO Corporation, Microsoft Corporation, Alphabet, Inc., Google LLC, Vimeo, LLC, X Corp., Inc., Pinterest, and Facebook (Meta Platforms, Inc.), to improve the user experience and targeted advertising. When visiting our site, data is transmitted to these companies, which may include viewing a page or specific content, adding payment information, or making a purchase.

Use of Third-Party Tracking Services and Technologies

In addition to our own cookies and tracking technologies, our site integrates and uses the following third-party tracking services and technologies to collect data, analytics, improve user experience, and targeted advertising:

• Albacross: Used for company identification and behavioral targeting.
• Facebook Pixel: Allows tracking of user actions after clicking on a Facebook ad, helps optimize advertising campaigns.
• GA4 (Google Analytics 4): Used to collect analytical data about user behavior on the site.
• Google Ads Conversion Tracking: Used to track conversions of Google Ads, which helps understand the effectiveness of advertising campaigns.
• LinkedIn: Helps track user interaction with advertising campaigns on LinkedIn.
• Zoho Sales IQ Live Chat: Used to provide real-time chat capability and track user interactions.
• Twitter Base Pixel: Tracks user activity for advertising targeting and analytics on Twitter.
• Crazy Egg: Provides heat maps and session recordings of user interactions on the site, helping to improve user interface and experience.

The use of these technologies allows us to better understand how users interact with our site and optimize our marketing and advertising efforts to provide more relevant and useful content.

You can refuse to accept browser cookies by activating the appropriate setting in your browser. However, if you select this setting, you may not have access to certain parts of the site. If you have not set your browser to refuse cookies, our system will issue cookies when you direct your browser to our site.

For information on how to manage cookie settings, click on the links below:

• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Internet Explorer
• Cookie settings in Safari

Data collected by the site and/or through cookies that may be placed on your computer will not be stored longer than is necessary to achieve the purposes mentioned above.

We may offer you the opportunity to share content from our Services on social networks or other communication channels. To support this, we connect with Bitly, AddToAny, and ShareThis, companies that provide content sharing services. Bitly, AddToAny, and ShareThis may set cookies or other tracking technologies on your computer or device. For more information, see Bitly's privacy policy, AddToAny's privacy policy, or ShareThis's privacy policy.

In some cases, we may embed or reference content hosted on YouTube. YouTube may set cookies or other tracking technologies on your computer or device. For more information, see YouTube's privacy policy.

Analytics of Our Services

Our websites may use Google Analytics, a web analytics service provided by Google, to better understand how you use our websites and how we can improve them. Google Analytics collects information such as how often users visit the website, which pages you visit when you do, and what other websites you used prior to visiting such a website. Google Analytics collects only the IP address assigned to you on the day you visit the website, not your name or other identifying information. Although Google Analytics sets a persistent cookie in your web browser to identify you as a unique user the next time you visit the website, the cookie cannot be used by anyone but Google. Google's ability to use and share information collected by Google Analytics about your visits to our websites is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. Google uses the data collected to track and examine the use of our websites, to prepare reports on its activities and share them with other Google services. To fully understand how Google may use data collected on our websites, please review the document "How Google uses data when you use our partners' sites or apps" (located here).

Please note: We currently do not respond to web browser "do not track" signals, which may allow you to opt-out of collecting information through networks of websites and online services. As described below, we respond to Global Privacy Control signals. You can learn more about setting this signal here: https://globalprivacycontrol.org/.

How We May Use Information

We may use the collected information for the following purposes:

• To respond to your inquiries;
• To provide you with services you have requested;
• To operate, troubleshoot, and improve the Services;
• To send you newsletters, updates, event information, marketing communications, and other information that may interest you;
• To maintain our contact list;
• To understand how people use our Services, including generating and analyzing statistics;
• For our business purposes, including data analysis; detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;
• To assess the effectiveness of our events, advertising campaigns, and publications;
• To evaluate, recruit, and hire staff;
• As necessary or appropriate to: comply with our legal obligations; respond to legal processes or requests for information issued by government authorities or other third parties; or protect your, our, or others' rights.

How We May Share Collected Information

CGIFlythrough is a global service provider. Our offices and business entities share information with each other for business purposes, such as internal administration, billing, promoting our events and services, and providing you or your organization with services.

We do not sell, rent, or otherwise share information that reasonably identifies you or your organization with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your prior permission.

We may also share information that does not reasonably identify you or your organization as permitted by applicable law.

We May Also Disclose Collected Information:

• To our third-party service providers who perform services on our behalf, such as web hosting companies, mail vendors, analytics providers, event organizing services, and information technology providers.
• To law enforcement, other government authorities, or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us; as provided by contract; or as we deem reasonably necessary to provide legal services. In these circumstances, we take reasonable efforts to notify you before we disclose information that may reasonably identify you or your organization, if prior notification is not prohibited by applicable law or is not impossible or unreasonable in the circumstances.
• To service providers, advisors, potential transaction partners, or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Grounds for Using Your Personal Information:

• Performance of Contract – We may collect and use your personal information to enter into a contract with you or to fulfill a contract you have with us. For example, when you use our Services, we will use your personal information to respond to your inquiries and provide you with such Services.
• Consent – We may use precise location information, as described in this privacy policy, if we obtain your consent before tracking such information. To withdraw your consent to such use, you can contact us through our "Contact Us" page, or you can disable the transmission of location information in your browser or mobile application settings. Where permitted by applicable laws, we will rely either on your consent or on legitimate interests for direct marketing.
• Legitimate Interests – We may use your personal information for our legitimate interests to improve our products and services and content on our Services. According to our legitimate interests and any options offered by us or consents required by applicable laws, we may use technical information, as described in this privacy policy, and use personal information for our marketing purposes.

Third-Party Services and Content

• Our Services may include integrated content or links to content provided by third parties (such as videos). This Privacy Policy does not address the privacy, security, or other practices of third parties providing such content.
• We interact with third parties that support the operation of our Services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms.

Protection and Storage of Collected Information

• While no information system is absolutely secure, we apply administrative, technical, and physical safeguards designed to comply with applicable legal requirements and protect the information we collect. This includes, where necessary, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equal to or exceeding that adopted by CGIFlythrough.
• We are not responsible for the security of information you transmit to us over networks that we do not control, including the internet and wireless networks.
• The Services are controlled and operated by CGIFlythrough from the United States. We may store the collected information in the United States or in other countries where we or our service providers have facilities. We may transfer information to countries outside your country of residence, including the United States, which may have data protection laws and regulations that differ from those in your country.
• We retain records and personal information for specific periods of time based on business needs, privacy interests, professional standards, instructions from our clients, and our obligations to comply with legislation. Generally, we retain personal information only as long as it is necessary or useful for achieving business or legal purposes. Cookies will be active depending on the type of cookie. See the "How We Use Cookies" section above for more information. After this period, personal information is deleted or fully anonymized.

Your Choices and Rights

If you no longer wish to receive marketing messages from us, you can let us know by sending us a letter to our email [email protected] . Electronic marketing messages we send to you may contain opt-out mechanisms allowing you to register your marketing preferences.

In accordance with local laws, you may have certain rights regarding the information we have collected that is related to you. We encourage you to contact us to update or correct your information if it changes or if you believe that any information we have collected about you is inaccurate. Depending on your jurisdiction, you may also request access to your personal information, its deletion, and inform us if you object to our use of your personal information. To protect your privacy, we take reasonable steps to verify your identity before providing access to your information. In some jurisdictions, you may have the right to file a complaint with your local data protection agency. If you wish to discuss or use any rights you may have, send us a letter to [email protected] or call us at +1 415 426 7110, providing your name, number, and details of your request.

How to Contact Us

We welcome your inquiries and comments. If you would like to contact us with questions about our privacy practices or data protection, please send us a letter to [email protected] or call us at +1 415 426 7110, providing your name, number, and details of your request. Please note that electronic communications are not necessarily secure; accordingly, you should not include confidential or sensitive information in your email correspondence with us. Additionally, please note that such communications are not intended to create an attorney-client relationship, and our Services are not intended for advertising or providing legal advice. If you wish to contact us regarding legal or other services, please contact one of our nearby offices. You can find a list of our offices on our main website https://cgiflythrough.com/.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The date of the last update to the current Privacy Policy is indicated at the bottom of this page. We encourage you to periodically review this page. If we make any material changes in the way we collect, use, and/or share the personal information that you have provided to us, we will notify you by posting a notice of the changes in a clear and conspicuous manner on the CGIFlythrough website.

For California Residents Only

This part of our Privacy Policy informs residents of California about the rights granted by the California Consumer Privacy Act, supplemented by the California Privacy Rights Act of 2020, along with its implementing regulations ("CCPA"), and how to exercise those rights. The rights outlined below apply to the part of our business in which we act as a business, not as a service provider under the CCPA. Please note that we may ask to verify your identity when we receive a request from you to exercise individual rights, to ensure the security of your personal information. All terms not defined in this part have the meanings defined under the CCPA.

Categories of Personal Information Collected About Consumers

During the 12-month period prior to the date of the last update to this Privacy Policy, we may have collected certain categories of personal information about consumers. These categories are defined and described below:

• Identifiers such as name, postal address, online/device identifier, IP address, email address, social media accounts, and information about social media accounts.
• Additional Personal Information described in section 1798.80 of the California Civil Code, such as signature, physical characteristics or description, telephone number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information.
• Commercial information such as transaction history, financial data, and payment information.
• Internet or other electronic network activity information such as browsing history and interaction with our websites, applications, systems, and emails.
• Geolocation data such as device location and IP location.
• Protected classification characteristics.
• Professional or employment-related information such as employer name and position/title.
• Education information such as student records.

We may also combine any of the above information and make inferences from this information to create a profile or resume about, for example, an individual's commercial preferences.

Categories of Sources from Which Personal Information is Collected

We may have collected personal information about you from the following categories of sources:

• Directly from you
• From our business partners and/or clients
• From third parties whom you have directed to share information with us

Business or Commercial Purpose for Collecting and Sharing Consumer Personal Information

During the 12-month period prior to the date of the last update of this Privacy Policy, we may have collected personal information and shared certain categories of personal information for any of the following business or commercial purposes:

• Providing you or your organization with Services
• Improving our Services
• Generating statistics on how people use our Services
• Among our offices and business entities for purposes such as internal administration and billing
• Interacting with you about events and services, marketing communications, and other information that may interest you
• Our third-party service providers who perform services on our behalf
• Making hiring decisions
• To law enforcement, other government agencies, or third parties (inside or outside the jurisdiction in which you reside) as necessary or as required by law
• To service providers, consultants, potential transaction partners, or other third parties in connection with a transaction or transfer of assets

Sale and Sharing

Personal information collected through cookies on the website, such as IP address and pages viewed, may be shared with third parties for targeted advertising purposes. As described below, you have the right to opt-out of the sharing of your personal information. You can exercise this right by contacting us through the provided contact information above, or through the use of Global Privacy Control signals, which can be found here: https://globalprivacycontrol.org/. We respond to these signals.

Retention Period of Your Information

We retain personal information about you for specific periods of time based on business needs, privacy interests, professional standards, instructions from our clients, and our obligations to comply with legislation. Generally, we retain personal information only as long as it is necessary or useful for achieving business or legal purposes.

If you have opted to receive marketing messages from us, we retain information about your marketing preferences until you opt-out of receiving these messages, in accordance with our policies. Cookies will be active depending on the type of cookie. See the "How We Use Cookies" section above for more information. After this period, personal information is deleted or fully anonymized.

CCPA Rights

If you are a California resident, you have the following rights regarding your personal information:

• Right to Know: The right to know what personal information we have collected about you, including the categories of personal information, the sources from which the personal information was collected, the business or commercial purposes for collecting, selling, or sharing such personal information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of personal information we have collected about you.
• Right to Delete: Subject to certain exceptions, the right to delete personal information that we have collected from you.
• Right to Access: The right to request disclosure of the practices for collecting and sharing personal information.
• Right to Correct Inaccurate Personal Information: The right to correct inaccurate personal information that we maintain about you.
• Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the sharing of your information with third parties. We use cookies to share information with third parties for targeted advertising purposes. To opt-out, please contact us using the contact information provided above or through the use of Global Privacy Control signals, which can be found here: https://globalprivacycontrol.org/. We respond to these signals.
• Right to Limit Disclosure of Sensitive Personal Information: We do not use your sensitive personal information for purposes other than the limited purposes permitted by California law, such as: (1) providing our services or goods, (2) identifying security incidents, (3) countering malicious, deceptive, fraudulent, or illegal actions, (4) ensuring physical safety, (5) for short-term temporary use, including some non-personalized advertising, (6) maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services, and (7) for verifying and maintaining the quality or safety of a service or product to improve, upgrade, or enhance the service or product.
• Right to Non-Discrimination: You have the right not to be discriminated against by us for exercising any of the rights provided by the CCPA.

How to Exercise Your CCPA Rights

• You may submit a request to us for specific information or to take certain actions, or you may authorize an agent to make such a request on your behalf. We will strive to verify your identity and/or your agent's authority when we receive a request from you or on your behalf to exercise individual rights, to ensure the security of your personal information.
• Please direct any requests to exercise your rights or any additional questions you may have regarding this Privacy Policy as indicated in the "How to Contact Us" section above. To opt-out of the sale/sharing of your personal information, you may also use the Global Privacy Control signals available here: https://globalprivacycontrol.org/.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The date of the last update to the current Privacy Policy is indicated at the bottom of this page. We encourage you to periodically review this page for updates. If we make any material changes in the way we collect, use, and/or share the personal information you have provided to us, we will notify you by posting a notice of the changes in a clear and conspicuous manner on the CGIFlythrough website.

Last updated: March 27, 2024