CPA Global Limited, Liberation House, Castle Street, St Helier, JE1 1BL, Jersey (“CPA Global”) is committed to protecting and respecting your privacy and your right to fair and just processing of your personal information. When you choose to provide us with information about yourself, we recognise that you trust us to act in a responsible manner. It is our objective to use the information you provide to provide you with better products and services.
We reserve the right to amend this policy from time to time and will provide visitors about whom we store personal information with notification of such changes.
CPA Global’s nominated representative for the purpose of the Act is Jennifer Aikins-Appiah.
Information we may collect from you
Our objective at CPA Global is to be your IP solutions provider of choice by providing you with the information and services that are most relevant to you. To achieve this goal, we need to collect information to understand what differentiates you from each of our other unique clients.
The website will gather information such as what kind of browser a visitor is on, what operating system they are using, their IP address, cookie information, time stamp (time page accessed as well as time spent per web page) and their clickstream information (for example, which pages they have viewed and how long they have been there). Note that information is only gathered while the visitor is on the website. The website monitors how a visitor arrives at the website, but cannot and will not gather information about other third party sites the user has visited. The website automatically receives and records such information on our server logs from your browser.
We may ask for Personally Identifiable Information (as defined below) to be entered as a means of registration before accessing a certain part of the website such as contacting us to pose questions, requesting information or completing a registration form.
“Personally Identifiable Information” means any information that identifies you personally, such as your name, e-mail address, password, login ID and other contact information that you voluntarily transmit with your communication to us.
Visitors to the website can choose not to enter any of their Personally Identifiable Information.
The website may also collect Personally Identifiable Information when you use certain CPA Global services, through the use of the website or hypersite web pages, or when you enter promotions or contests offered by CPA Global on and through the website.
IP Addresses and Cookies
We may where you have consented for us to do so collect information about your computer including where available your IP address, operating system and browser type for system administration. This is data about our visitors’ browsing actions and patterns and may also identify individuals.
For the same reason we may obtain where you have consented information about your general Internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our web site and to deliver a better and more personalised service. They enable us to:
Estimate our audience size and usage pattern;
Store information about your preferences and so allow us to customise this web site according to your individual interests;
Speed up your searches;
Recognise you when you return to this web site.
You may refuse to accept cookies by activating the setting on your browser, which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of this web site
Where we store your personal data
The data we collect from you will be transferred to and stored at a destination outside the European Economic Area. By using this web site, participating in any of our services and/or providing us with your information, you consent to this transfer. All information you provide to us is stored on our secure servers. Such data will be stored in accordance with all relevant data protection laws including the Data Protection Act 1998.
Unfortunately, the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your personal data, we cannot ensure the security of data transmitted by you to this web site. Any transmission is at your own risk. Once we have received your information we will use security procedures and features to prevent unauthorised access to it.
Uses made of the information
We may use information we hold about you in the following ways for the purpose of internal administration and to ensure that the content on this web site is presented in the most effective manner for you and for your computer in order to:
Allow us to verify your username and password on login to certain restricted areas of the web site;
Provide you with information, products or services that you request from us or which we consider may interest you, such as important changes to this web site, new CPA Global services or changes to existing services and special offers we think you will find valuable;
Allow you to participate in interactive features of our service where you choose to do so.
CPA Global uses your Personally Identifiable Information to register you to use CPA Global’s services, contact you to deliver certain services or information you have requested, verify your authority to enter into certain areas of the website, improve the content and general administration of the website and our services, provide you with notices regarding our services and understand our visitors and, with permission, provide visitors with updates on CPA Global and its services.
The website may track information that will be maintained, used and disclosed in aggregate form only and which will not contain your personally identifiable information, for example, without limitation, the total number of visitors to our website, the number of visitors to each page of our website, browser type, External Web Sites (as defined below) linked to and IP addresses. CPA Global may analyse this data for trends and statistics in the aggregate, and we may use such aggregate information to administer the website, track users’ movement, and gather broad demographic information for aggregate use.
We may, where appropriate to meet the purposes described in this policy, disclose your personal information to any member of our group which means any company which is a holding company or subsidiary of CPA Global limited and any holding company or subsidiary of such holding company (the “CPA Global Group“). We will not disclose your personal data to any company outside the CPA Global Group.
We will only disclose your personal information to third parties under the following conditions:
If we are required to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our Terms and Conditions or any other agreement; or protect the rights, property, or safety of CPA Global , our customers, or others. This includes exchanging information with other companies and organisations for protection against credit risk and fraud;
In the event that we sell or buy any business or assets in which case we may disclose your personal data to the seller or buyer of such business or assets;
If CPA Global or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will of course be one of the transferred assets;
With your specific consent either at the time you register with this web site, or subsequently.
If you would rather not receive any further information from us please complete our online contact form and ask to be removed from our mailing lists. If possible, please include a copy of the communication you received to help facilitate a timely and accurate removal.
Access to information
The Act gives you various rights including the right to access information held about you.
It is very important to us that your experience using cpaglobal.com is positive. We respect your rights to privacy and the fair and just processing of your personal information.
CPA Global Customers: Privacy and Data Protection Update
The European Court of Justice (CJEU) handed down a decision on October 6, 2015, invalidating the EU-US Safe Harbor Framework for personal data transferred from the EU to the US. CPA Global recognizes the importance to its Customers of the treatment of personal data and can provide reassurance that it will continue to comply with data privacy protections already in place, and take any steps necessary in the future to ensure compliance.
Any references to the certification we hold under the Safe Harbor Framework should be read in the context of this update.
Common Questions and Answers:
What did the European Court of Justice decide regarding the EU-US Safe Harbor Framework?
On October 6, 2015, the European Court of Justice determined that the EU-US Safe Harbor Framework does not provide a valid legal basis for transfers of personal data from the EU to the US.
What is the EU-US Safe Harbor Framework?
The EU-US Safe Harbor Framework was established by the European Commission and the U.S. Department of Commerce in 2000 as a certification regime to allow transfers of personal data from the EU to certified U.S. companies.
So what happens now?
The CJEU has effectively invalidated the safe harbor provision and returned the issue to the hands of regulators in each country. Each EU member nation will now make its own decisions about how to interact with the US on such issues. Previous discussions between the US and EU about an updated Safe Harbour 2.0 agreement could be sped up by these recent developments.
What does the European Court of Justice’s decision mean for my company’s relationship with CPA Global?
CPA Global has taken great strides to build strong data protection controls and is confident that it provides an adequate level of protection to any personal data provided to it by its Customers. In the coming days we will propose a suitable alternative method to the Safe Harbor Framework to ensure compliance with the European Commission’s requirements. One possibility is for our companies to enter into standard terms (known as “model clauses”) to enshrine the protection of personal data in a written contract. Any use of the model clauses will apply to the extent there is not another legal basis in place to validate the transfer of personal data from the EU to the U.S.
Where can I get additional information?
Additional information about the EU-US Safe Harbor Framework including the Safe Harbor principles is available at the U.S. Department of Commerce’s Web site.
What if I have additional questions?
Please contact your CPA Global customer support team via the normal channels who will be able to assist or redirect your query as appropriate.
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