Cookies and Privacy

A. Introduction

The privacy of our website visitors is very important to us, and we are committed to safeguarding it. This policy explains what we will do with your personal information. Consenting to our use of cookies in accordance with the terms of this policy when you first visit our website permits us to use cookies every time you visit our website.


B. Credit

This document was created using a template from SEQ Legal (seqlegal.com) and modified by Website Planet (www.websiteplanet.com).


C. Collecting personal information

The following types of personal information may be collected, stored, and used by first parties (C-SEP) and third parties (Google/Gmail, MailChimp, Survey Monkey, and GitHub):

information about your computer including your IP address, geographical location, browser type and version, and operating system;
information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
information, such as your email address, that you enter when you register with our website;
information, such as your name and email address, that you enter in order to set up subscriptions to our emails and/or newsletters;
information that you enter while using the services on our website;
information that is generated while using our website, including when, how often, and under what circumstances you use it;
information contained in any communications that you send to us by email or through our website, including its communication content and metadata;
any other personal information that you send to us.
Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy


D. Using your personal information

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for the following:

administering our website and business;
personalizing our website for you;
enabling your use of the services available on our website;
sending you email notifications that you have specifically requested;
sending you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
dealing with inquiries and complaints made by or about you relating to our website;


If you submit personal information for publication on our website, we will use that information (your name and email address) in accordance with the license you grant to us. Publications and emails are managed through third party entities, Gmail and MailChimp, and these entities are responsible for security and privacy of the data collected therein.

Your privacy settings can be adjusted using privacy controls on the website, as well as those on your internet browser.

We will not, without your express consent, supply your personal information to any third party for their or any other third party’s direct marketing.

Visitors who participate in surveys hosted by C-SEP, browse our Google Calendar, or contact us via email or our message form will be interacting with us through a third party (Google/Gmail; MailChimp; Survey Monkey).


E. Disclosing personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy. We do not share our mailing list with third parties, beyond those incorporated into our structure (Gmail, Survey Monkey, MailChimp).


We may disclose your personal information only on the following legal conditions:

to the extent that we are required to do so by law;
in connection with any ongoing or prospective legal proceedings;
in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.


F. International data transfers

Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy. Information that we collect is stored in the the United States.


G. Retaining personal information

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary. Without prejudice to article G-2, we will delete personal data falling within the categories set out below at the date/time set out below: personal data type (name and email address) are deleted immediately upon the time for which this data is no longer necessary; more specifically, after a query or comment has been answered and the individual does not/or no longer wishes to receive newsletters. In the former case, the email is deleted and purged from our Gmail account. In the latter case, where an individual wishes to be removed from our mailing list, personal data is deleted and purged immediately following the receipt of a written request to purge this data via the email account you wish to be remove.


H. Security of your personal information

We take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
We store all the personal information you provide us (your name and email address) on our secure (password- and firewall-protected) servers operated by Gmail and MailChimp.
You acknowledge that the transmission of information over the internet via email and message forms is inherently insecure, and we cannot guarantee the security of data sent in this manner.


I. Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.


J. Your rights


You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the following:

the supply of appropriate evidence of your identity (for this purpose, we will accept a photocopy of your passport certified by a notary) and an email from the matching account you wish to acquire information on.

You may instruct us at any time to delete and purge any data we have collected on you.

In practice, you will usually expressly agree in advance to our use of your personal information.


K. Third party websites

Our website includes hyperlinks to, and utilizes the services of, third party entities to manage our interaction and services. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
This website includes Google Calendar for our upcoming training events, who may track visitors and collect data on individuals who browse the calendar for the purpose of targeted advertising and profiling;
a a link to Survey Monkey to participate in an online survey about C-SEP, who may track visitors and collect data on individuals that participate in surveys hosted by them for their own marketing and profiling;
b a contact form and email link where visitors can make comments or queries to C-SEP through Gmail and MailChimp, and these entities may track visitors and collect data for their own marketing or profiling purposes;
c and finally, a link to HTML5/GitHub which produced the free template this website is designed around, who may track or collect data on individuals that link to the website for their own profiling and marketing purposes.

To access the privacy policy of our third party entities, we recoomend the following resources:

Google / Gmail policy is available at https://policies.google.com/privacy
MailChimp policy is available at https://mailchimp.com/legal/privacy/
Survey Monkey policy is available at https://it.surveymonkey.com/mp/legal/privacy-policy/
GitHub policy is available at https://help.github.com/articles/github-privacy-statement/


L. Updating information

Please let us know if the personal information that we hold about you (name and email address) needs to be corrected or updated.


M. Cookies

Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. We use only session cookies on our website.


The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:

We only use session cookies that aide in general navigation within the website and optimize your internet experiece. C-SEP does not track users, we do not host third-party advertisers, or collect or store any information on visitors. However, Google does track individuals that browse the Google Calendar, and Gmail/MailChimp will acquire some of your data if you interact with us.

If you wish to opt out of cookies, most browsers allow you to refuse to accept them. To opt out:


a. in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools,” “Internet Options,” “Privacy,” and then “Advanced”;
b. in Firefox (version 24) you can block all cookies by clicking “Tools,” “Options,” “Privacy,” selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
c. in Chrome (version 29), you can block all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Content settings,” and then selecting “Block sites from setting any data” under the “Cookies” heading.
Note: Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.


You can also delete cookies already stored on your computer. To do so:


a. in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835 );
b. in Firefox (version 24), you can delete cookies by clicking “Tools,” “Options,” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies,” and then clicking “Remove All Cookies”; and
c. in Chrome (version 29), you can delete all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Clear browsing data,” and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data.”
Note: Deleting cookies will have a negative impact on the usability of many websites.