Data Privacy Department Contact Information

For more information about CCI’s information practices, please view the Company’s full Privacy Statement below. Questions regarding CCI’s Privacy Statement or information practices should be emailed to dataprivacy@opti.co, or you may write to us at:

Data Privacy Department Contact Information

Communication Constructs, Inc.

Data Privacy Department

P.O. Box 56967

Albuquerque, New Mexico 87187

Communication Constructs, Inc. (CCI), d/b/a Opti.Co, d/b/a Comunico Privacy Statement
Privacy Statement Highlights Important Information

CCI’s full Privacy Statement contains more information about the Company’s Website privacy practices.
CCI is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Information collected
When you request additional information or register on CCI’s Web site, the Company will ask you to provide basic contact information.
When you purchase CCI’s applications or services (the “Services”), the Company will ask you to provide billing information. CCI uses common internet technologies, such as cookies and Web beacons, to keep track of interactions with the Company's Web sites and emails.
When you register for or attend corporate events, the Company will ask you to provide basic contact information, billing information, and information on your participation in the events on CCI’s web sites.
CCI uses common internet technologies, such as cookies and web beacons to keep track of interactions with the Company's websites and emails.

Use of information
CCI uses information collected to provide you with the services you request.
CCI does not share, sell, rent, or trade personally identifiable information with third parties for their promotional purposes. CCI may share information collected with other companies that work on CCI’s behalf.

CCI may use information collected to:
1. Improve the Company’s Web sites and Services.
2. Provide you with additional information about the Company’s partners, promotions, and events.
3. Share information collected with other companies that work on CCI’s behalf.

Customer Data

Customers of CCI may electronically submit data or information to the Company’s services (“Customer Data”).
CCI will not review, share, distribute, or reference any such Customer Data except in compliance with CCI Data Privacy Policy. CCI accesses Customer Data only for the purposes of providing the services, preventing or addressing service or technical problems, at a Customer’s request in connection with customer support matters, or as may be required by law.

Choice
CCI offers individuals the opportunity to choose (opt out) whether their personal information is (a) to be disclosed to a third party or (b) to be used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual. Individuals must be provided with clear and conspicuous, readily available, and affordable mechanisms to exercise choice.

For sensitive information (i.e. personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual), they must be given affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual through the exercise of opt in choice. In any case, an organization should treat as sensitive any information received from a third party where the third party treats and identifies it as sensitive.

How to contact us for more information about CCI’s information practices, please view the Company’s full Privacy Statement. Questions regarding CCI’s Privacy Statement or information practices should be emailed to dataprivacy@opti.co, or you may write to us at:

Communication Constructs, Inc.
Data Privacy Department
P.O. Box 56967
Albuquerque, New Mexico 87187

Privacy Statement, effective as of February 13, 2019

CCI, Inc. (“CCI” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”), and individuals who register to attend the Company’s corporate events (“Attendees”). This Privacy Statement describes CCI’s privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by CCI (the “Services”).

1. Web sites covered
This Privacy Statement covers the information practices of websites that link to this Privacy Statement, including: http://www.opti.co, http://mobilservpowerwriter.com, http://www.comunico.global. CCI’s Web sites may contain links to other websites. The information practices or the content of such other websites is governed by the privacy statements of such other websites. The Company encourages you to review the privacy statements of other websites to understand their information practices.

2. Information collected
When expressing an interest in obtaining additional information about the Services or registering to use the Services, CCI requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services, CCI may require you to provide the Company with billing information, such as billing name and address, number of employees within the organization that will be using the Services (“Billing Information”). CCI may also ask you to provide additional information, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information about Customers are referred to collectively as “Data about CCI Customers”.

As you navigate the Company’s Web sites, CCI may also collect information through the use of commonly-used information-gathering tools, such as cookies. Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked).

3. Use of Information Collected
The Company uses Data about CCI Customers to perform the services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Services.

The Company may also use Data about CCI Customers for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, its affiliates, and its partners, such as information about promotions or events.

4. Web Site Navigational Information
IP Addresses
When you visit CCI’s Web sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, CCI uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites.

5. Public forums, refer a friend, and customer testimonials
CCI may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. CCI is not responsible for the personal information you choose to submit in these forums.

Customers and Visitors may elect to use the Company’s referral program to inform friends about the Company’s Web sites. When using the referral program, the Company requests the friend’s name and email address. CCI may send the friend a one-time email inviting him or her to visit the Company’s Web sites. CCI does not store this information.

CCI posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. CCI obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

6. Sharing of information collected
Service Providers
CCI may share Data about CCI Customers with the Company's contracted service providers so that these service providers can provide services on our behalf. Unless described in this Privacy Statement, CCI does not share, sell, rent, or trade any information with third parties for their promotional purposes.

Compelled Disclosure
CCI reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with national security, judicial proceeding, court order, law enforcement requirements or legal process.

Accountability for Onward Transfers
CCI complies with Notice and Choice Principles as outlined above.

If CCI contracts with third parties in performing certain screening or informational services in accordance with intended purposes outlined above. CCI maintains a formal process to identify and credential prospective third parties and requires approved third parties to execute agreements.

CCI, and third parties acting on its behalf, shall undertake reasonable steps to prevent unauthorized or accidental destruction, alteration or disclosure of, accidental loss of, unauthorized access to, misuse of, unlawful processing of, or damage to, the personal information that is collected about individuals for the intended purposes defined above.

Before CCI transfers information to a third party acting as a “controller” (defined as a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal data), CCI will enter into a contract with the third-party controller that provides that personal information may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the Principles and will notify CCI if it makes a determination that it can no longer meet this obligation. The contract provides that when such a determination is made the third party controller will cease processing or take other reasonable and appropriate steps to remediate.

Before CCI transfers information to a third party acting as an agent, CCI will (i) transfer such data only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with CCI’s obligations under the Principles; (iv) require the agent to notify CCI if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department upon request.

7. International transfer of information collected
To facilitate CCI’s global operations, the Company may transfer and access Data about CCI from around the world, including the United States. This Privacy Statement shall apply even if CCI transfers Data about CCI Customers to other countries.

8. Communications preferences
CCI offers Visitors and Customers who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by sending a request specifying your communications preferences to dataprivacey@communicationcreator.com. Customers cannot opt out of receiving transactional emails related to their account with CCI.

9. Correcting and updating your information
CCI provides Customers with reasonable access to their Personal Information. We provide a reasonable opportunity for Customers to correct, amend or delete information where inaccurate.
To obtain access to Personal Information, Customer may contact CCI as specified in Section 13. Contact us paragraph of this statement.

10. Customer Data
CCI Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). CCI will only review, share, distribute, or reference any such Customer Data only in accordance with CCI Data Privacy policy, or as may be required by law. CCI may access Customer Data only for the purpose of providing the Services, preventing or addressing service or technical problems, at a Customer’s request in connection with customer support matters, or as may be required by law.

11. Security
CCI uses robust security measures to protect Customer Data from unauthorized access, disclosure, alteration or destruction, maintain data accuracy, and help ensure the appropriate use of Customer Data. These technologies help ensure that Customer Data is safe, secure, and only available to the Customer to whom the information belongs and those to whom the Customer has granted access. CCI hosts its Web sites in a secure server environment that uses firewalls, intrusion detection systems, and other advanced technology to prevent interference or access from outside intruders. Customers are responsible for maintaining the security and confidentiality of their CCI usernames and passwords.

12. Changes to this Privacy Statement
CCI reserves the right to change this Privacy Statement. CCI will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.

13. Contact us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be emailed to dataprivacy@opti.co or you may write to us at:

Communication Constructs, Inc.
Data Privacy Department
P.O. Box 56967
Albuquerque, New Mexico 87187