Privacy Notice

Czarnowski Display Service, Inc. and its affiliates and subsidiaries (“Czarnowski,” “we,” “us,” or “our”) respect your privacy. This Privacy Notice describes the processing of Personal Information (defined below) that is provided, collected, or disclosed in the course of providing our services to you (“Services”) and on the websites, applications, and other platforms that link to this Privacy Notice (“Site”), including when you apply for a job with us. It also describes rights you may have under applicable laws. Please read this Notice carefully to understand our policies and practices regarding your Personal Information and how we will treat it.

Personal Information We Collect

We collect several categories of Personal Information from and about our customers, prospective customers, and users of our Site. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The categories of Personal Information we collect may include:

• Contact Information – If you submit an inquiry, register for an account, register for an event, or provide information on or through our Site, we may collect your contact information including your name, address, email address, and phone number.
• Commercial Information – If you submit an inquiry, or provide information on our Site, we may collect commercial information including Services you have shown interest in.
• Usage Information – When you use our Site, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the website you visited before coming to our Site), domain names associated with your internet service provider, and any other information regarding your interaction with our Site.
• Employment Information – If you apply for employment with us, we will collect Personal Information related to your potential employment, including your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
• Communication Information – We may collect any Personal Information contained within your communications with us with us via email, telephone, or otherwise, and in certain cases we may use third-party service providers to do so. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees.

How We Collect Personal Information

Directly From You –We collect Personal Information that you provide to us, for example, if you choose to contact us, request information from us, or sign up to receive updates.

From Third Parties – We may collect Personal Information from third parties including, business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.

Through Online Tracking Technologies – We use cookies and similar technologies to collect Personal Information related to activity on our Site. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.

How We Use Personal Information

To the extent permitted by applicable law, we use Personal Information:

• To provide our Services, including providing customer service, verifying customer information, maintaining our business records, and undertaking or providing similar services.
• For internal research and development, such as testing, verifying, and improving the quality of our Site and Services.
• For marketing and advertising, including using your information to send you messages, notices, newsletters, surveys, promotions, or event invitations about our own or third parties’ goods and services that may be of interest to you. We also use Personal Information to conduct interest-based advertising as discussed in the Cookies and Other Tracking Technologies section below. You can unsubscribe from any marketing emails that we may send you by following the instructions included in the email correspondence.
• For communicating with you, such as responding to your questions, concerns, and comments.
• For legal, security, or safety reasons, such as protecting our and our customers’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
• As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.
• To fulfill any other purpose for which you provide it, including purposes described when you provide the information or give your consent.

If you are applying for employment with us, we also use Personal Information to process your job application, to verify the information you have provided in your application, conduct interviews, perform background and reference checks, to communicate with you and answer your questions, to confirm your eligibility for employment, and improve our recruiting processes. We may also save your Personal Information for future employment opportunities with us.

How We Disclose Personal Information

We may disclose aggregated information about our customers and information that does not identify any individual, without restriction.

We may disclose Personal Information in the following circumstances:

Employees and Other Personnel – We may share Personal Information with our employees and personnel (such as contractors) who have a need to know the information for our business purposes.

Service Providers – We disclose your Personal Information with the service providers that we use to support our business, including but not limited to, data analytics providers, website hosting providers, and other technology providers. If you are applying for a job with us, this may include service providers such as background check providers and human resource providers.

Affiliates and Subsidiaries – We may disclose your information to the Czarnowski family of companies for their and our business purposes and for marketing purposes, including to provide you information about our Services.

Business Partners – We may disclose Personal Information with trusted business partners or corporate affiliates. For example, we may disclose your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with.

Ad Tech Companies and Other Providers – We may share or make available limited Personal Information (such as a mobile device identifiers) with ad tech companies and other online service providers. When we share your Personal Information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.

Legal Obligation or Safety Reasons –We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Czarnowski, its employees and customers, or the public against harm.

Merger or Change of Control –We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you notice prior to such disclosure.

Other – We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

Phone numbers we collect will not be shared with third parties or affiliates for marketing or promotional purposes. Any other mentions in this Privacy Notice exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties except our vendors and other service providers who need this information to send messages on our behalf.

Cookies and Other Tracking Technologies

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Site. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Site, to enhance your experience through personalization, and to help us better understand the features of our Site that you and other users are most interested in.

Website Delivery and Appearance – We may use third-party providers to enable certain customer interaction opportunities, content delivery, or other service capabilities. For example,we partner with companies like YouTube to deliver specific content delivery like audio and video. For more information about how YouTube collects and uses your data, visit Google’s Privacy Policy.

Website Analytics – We use analytics services that use cookies and other technologies that collect your Personal Information, to assist us with analyzing our Site traffic and site usage to optimize, maintain, and secure our Site and inform subsequent business decisions. These include, but are not limited to, Google Analytics. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

Interest-Based Advertising – We may also allow or enable third parties to collect Personal Information to provide their interest-based advertising on behalf of our products and services, or their own. Interest-based advertising occurs when advertisements are shown to you based on information collected from your online interactions over time and across multiple websites, devices, or online services that you visit or use. Some companies may engage in cross-context behavioral advertising to predict your preferences and show you advertisements that are most likely to be of interest or relevant to you.

We do not control these third parties’ collection or use of your information for these purposes, or the opt-out options they may individually offer you via their terms, conditions, and privacy policies. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Examples of the third-party service providers we engage to serve interest-based advertisements include Google, AppNexus, and ZoomInfo. It is in this context that we may provide advertising networks, data analytics providers, social networks, and video sharing platforms with Personal Information such as your IP address, device information, Internet and other electronic network activity information, and geolocation information in the last twelve months.

Selling Personal Information – While we do not sell Personal Information in exchange for monetary consideration, we do disclose Personal Information for other benefits that could be deemed a “sale” ““under various data protection laws because it is sometimes broadly defined to include activities such as the delivery of interest-based advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.

Cookie Choices – To manage your preferences with respect to these technologies, you can:

• Change your cookie preferences by clicking “Cookie Settings” or customizing your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Site may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.
• Block the collection and use of your information by online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the opt out pages of the self-regulatory programs of which those companies are members: National Advertising Initiative and Digital Advertising Alliance (or the European Interactive Digital Advertising Alliance, if you are located in the European Economic Area). Please note that even if you opt out of interest-based advertising, you may still see “contextual” ads which are based on the context of what you are looking at on the websites and pages you visit.
• Review and execute any provider-specific instructions to customize your preferences or opt-out of certain processing, including interest-based advertising, by third-party service providers. For example, to opt-out of this type of advertising by Google, customize your ad preferences, or limit Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions.

How Long We Keep Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes described in this Privacy Notice, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your Personal Information include whether we need your Personal Information to provide you with our Services; you have requested information from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or recordkeeping policies and obligations dictate that we retain your Personal Information; we have an interest in providing you with information about our Services; or we have another business purpose for retaining your Personal Information.

How We Protect Personal Information

We use commercially reasonable efforts to protect the confidentiality and security of Personal Information. However, despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.

International Use and Cross Border Data Transfers

Our Site is hosted in the United States. If you are visiting our Site from outside of the United States, please note that by providing your Personal Information, it is being transferred to, stored, collected, or processed in the United States, where our servers are located and operated.

For individuals in the European Union, European Economic Area, Switzerland, and United Kingdom: Czarnowski will only transfer Personal Information to third parties located outside of this region when it has ensured appropriate safeguards for such Personal Information through use of the standard contractual clauses or other lawful and approved methods. To request a copy of applicable cross-border data transfer agreements, please reach out using the information in the Contact Us section.

Links to Third-Party Websites

We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be handled in accordance with the applicable third party’s privacy policy.

Exercising Your Privacy Rights

Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:

• Access – The right to request access to and obtain a copy of any Personal Information we may have about you.
• Deletion – The right to delete your Personal Information that we have collected or obtained, subject to certain exceptions.
• Correction – The right to request that we correct any inaccuracies in your Personal Information, subject to certain exceptions.
• Opt Out of Certain Processing – The right to: (a) opt out of the processing of your Personal Information for purposes of targeted or cross-context behavioral advertising, (b) opt out of the sale of your Personal Information, and (c) limit the use of your sensitive Personal Information (if applicable). We do not collect or process sensitive Personal Information outside of purposes permitted by law (such as section 7027(m) under the California Consumer Privacy Act Regulations), so we do not offer the option to limit its use.
• Objection/Restriction of Processing – The right to object or restrict us from processing your Personal Information in certain circumstances.
• Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information.
• Automated Decision-Making – The right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right, depending on your location, to consent or opt out of (a) this automated decision-making or (b) any profiling in furtherance of decisions that produce legal or similarly significant effects. We do not profile you or other individuals in a manner that would result in legal or similarly significant effects, or engage in automated decision-making, so we do not offer an opt out of such activity.
• Lodge a Complaint ­– The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

To exercise any of the privacy rights afforded to you under applicable data protection laws, please submit a request to us by calling us at (800) 247-4302 or e-mailing us at compliance@czarnowski.com.

You may also initiate any opt outs by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). We honor Opt-Out Preference Signals, including GPC. If you choose to use an Opt-Out Preference Signal, you will need to turn it on for each supported browser or browser extension you use.

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Notice which means we will not deny goods or Services to you, provide different prices or rates for goods or Services to you, or provide a different level or quality of goods or Services to you. Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.

We must verify your identity before fulfilling your requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

Children’s Privacy

We do not knowingly collect or solicit any Personal Information from children under the age of 13 without verified written parental consent. In the event that we learn that we have collected Personal Information from a child under the age of 13, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at compliane@czarnowski.com.

Individuals in the European Union, European Economic Area, Switzerland, and the United Kingdom

This section provides additional information regarding Czarnowski’s processing of personal data of people located in the European Union (EU), European Economic Area (EEA), Switzerland, and the United Kingdom (UK) in accordance with the EU Data Protection Regulation, UK Data Protection Regulation, and the Swiss Federal Data Protection Act.

Legal Bases for Processing

Our legal basis for processing Personal Information depends on the Personal Information involved and the context in which we process it. Where Czarnowski acts as a controller, we process your Personal Information: with your consent; where necessary to perform a contract; to comply with our legal obligations; and where doing so is in our legitimate interests (including the purposes described in this Notice) and such interests are not outweighed by your rights and freedoms.

Special Category Data

Czarnowski only collects Special Category Data where we have a lawful basis for doing so that is permitted under Article 9 of the GDPR, specifically within the employment context. If you apply for a job with us, we may collect data that reveals your racial or ethnic origin, trade union membership, sexual orientation, or health to fulfill our obligations, exercise our rights, and otherwise administer our employment relationship with you (including initial recruitment and hiring, where applicable). For example, we may collect health information to make reasonable disability accommodations; immigration information to verify your right to work in a particular jurisdiction; and data points like your race, ethnicity, and sexual orientation to monitor equal opportunities. Please refrain from sending us any Special Category Data outside this employment context.

For additional information about Czarnowski’s compliance with, and your rights under, the GDPR, please see our GDPR Notices.

California Residents

This section provides additional information regarding Czarnowski’s practices pursuant to the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.

Please see the below chart for detailed information about the categories of Personal Information we have collected from California residents during the twelve months preceding the date on which this Notice was last updated and the categories of third parties to whom we Sell or Share Personal Information (as those terms are defined in the CCPA). For each category of Personal Information set forth in the chart below, the categories of third parties to whom we disclose it for a business or commercial purpose are set forth in the How We Disclose Personal Information section above.

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