Citizen Relations Inc. Privacy Policy (US)

Last Updated: Sep 2024

Citizen Relations Inc. (referred to here as “Citizen” or “we” or “us”) values our customers and respects your privacy.

This Privacy Policy (“Policy”) applies to our offline and online data collection practices, including when you visit our website at www.citizenrelations.com and any website owned, operated, or controlled by us (collectively the “Site”), contact us by phone or email, or when you engage with us on social media.

We may update this Policy from time to time, as specified in the “Changes to This Privacy Policy” section below.

California state law confers certain rights relating to personal information to its residents.  If you are a California resident, please also see our California Consumer Privacy Section in this Policy located here.

If you are a Texas resident, please also see our Texas Data Privacy and Security Act Notice located here. 

Your Consent

You should read this entire Policy before submitting information to us or using our Site.  Whenever you submit personal information to us, you consent to the collection, use, disclosure, transfer and storage of that information in accordance with this  Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form. 

Information Collection and Use

We collect personal information using three methods: 1) from you when you choose to voluntarily provide it; 2) using automated technology, including when you visit our Site or communicate with us through email; and 3) through third party sources including but not limited to service providers, entities providing data analysis and analytics, social media and social networking websites and other entities.   

All personal information will be used as stated in this Policy.  We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.

We may combine data collected from these disparate sources unless we tell you otherwise.

We collect, use, and disclose your personal information as described in the chart in Annex 1 below.

Retention of Data

We will retain your personal information (collected through offline and online methods) for as long as it is necessary for the purposes described in this Policy. We will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Intended Audience of Site; COPPA Compliance

We are in compliance with the requirements of the Children’s Online Privacy Protection Act (“COPPA”) and other applicable privacy laws. Our Site, social media accounts and online activities are not directed to children under the age of 16. As a result, our Site does not request or knowingly collect personal data from individuals under the age of 16. If you are not 17 or older, you should not visit or use our Site.   

Security

We take reasonable appropriate steps to protect personal data from loss, misuse and unauthorized access, disclosure, alteration or destruction, whether in transmission or storage. Please keep in mind, however, that there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free.

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology hosted by a third party and then encrypted into our payment gateway provider’s database only to be accessible by those authorized with special access rights to such systems, and who are required to keep the information confidential.

Cookies and other automated technology

A “cookie” is a small text file that is placed onto an Internet user’s web browser or device and is used to remember and/or obtain information about the user. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags.

To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.

ANALYTICS DISCLAIMER

We and/or third parties including our service providers on our behalf, may use cookies, web beacons and other similar technology, to collect information for the purposes described in this privacy statement including analytics, and monitoring performance and improvement of our Site (traffic, errors, page load time, popular pages, etc.) 

We use Google Analytics to understand how our Site, services, and products perform and how you use them. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy. To opt out of Google Analytics please visit https://tools.google.com/dlpage/gaoptout

Contact for More Information

For information and questions about the use of your personal information or this Policy, you may contact us at privacy@citizenrelations.com.

Changes to This Privacy Policy

This Policy may be revised from time to time for any reason.  If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page.  Be sure to check the Policy whenever you submit personal information or use our Site, services, or engage with our social media accounts.  The effective date of this Privacy Policy is January 1st, 2023.

CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).  If you are not a California resident, this Notice does not apply to you.

Your Rights and Choices and How To Exercise Them

The CCPA provides Califorinia consumers with speciific rights regarding their Personal Information. This section describes your CCPA and CPRA rights and explains how to exercise those rights. 

Information Collected 

Within the past 12 months, we have collected the categories of personal information about California consumers as described in Annex 1 to this Notice.

Business-to-Business (“B2B”) Information

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, you have the same rights as other consumers set forth in this Notice with respect to the information we collect from you in that role.  We collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information and communications consistent with your role in facilitating that business relationship.  We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.  We do not disclose that information outside our business relationship without your consent.  For more details see Annex 1.

Information Sold or Shared

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding 12 months.

We have disclosed the following category of personal information to third parties for a business or commercial purpose in the preceding 12 months:

  • Internet/Network Activity.

For details regarding categories of third parties with whom we have disclosed this information, please see Annex 1.

We do not knowingly sell or share the personal information of minors under 16 years of age.

Requests to Know

You have the right to request that we disclose personal information we collect about you.

To make a request for any of the information set forth in  Annex 1. (a “Request to Know”), please  see our section below on submitting Requests.

Right to Know and Limit Use of Sensitive Personal Information Collected

We do not collect your sensitive personal information, and we do not collect or process sensitive personal information for purposes of inferring characteristics or for any purposes other than those set forth in Regulations Section 7027(m). 

Right to Request Deletion of Personal Information

You have the right to request the deletion of your personal information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.

To make a Request to Delete,  please see our section below on submitting Requests.

Right to Correct

You have the right to request that we rectify inaccurate information about you. To make a Request to Correct, please see below on how to make Requests. 

Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of your personal information.  We do not sell or share your personal information.

Cookies

You can opt out of cookies using your browser.  Additionally, you may also exercise your right to opt-out of cookies and automated technology used by Company and third party partners using the opt-out methods identified in Section 3.

Please Note:

  • Opt-outs are device and browser based.  You must opt out on each device and each browser where you want your choice to apply.
  • Opt-outs maybe stored via cookies.  If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
  • We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our website, credit card processors, analytics processors.  These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
  • You may still receive ads from us that are not tailored to your interests.

Right to Non-Discrimination For Exercising Consumer Privacy Rights

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.

Right to Access Information About Automated Decision Making and the Right to Opt-Out of Automated Decision Making

You can request access to information about automated decision making processes.  Citizen does not engage in automated decision making processes.  To inquire about automated decision making, please email us at privacy@citizenrelations.com.

How to Make a Rights Request to Know, Delete, or Correct

You can make a Rights Request in the following ways: 

We will acknowledge your Request within 10 days and will attempt to respond substantively within 45-90 days. 

You must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. 

Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us verify your identity. 

We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law. 

Retention of Personal Information

We will retain your personal information for as long as it is necessary for the purposes set out in Annex 1 and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your personal information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Authorized Agent Information

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

Authorized agents may make requests under the California Consumer Privacy Act on behalf of consumers by emailing privacy@citizenrelations.com . We will require authorized agents to provide proof of the consumer’s consent to and designation of the authorized agent for purpose of making the request, and will require authorized agents to provide information necessary to verify the identity of the consumer who is the subject of the request. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.

California Do Not Track Notice

Because there are not yet common, industry accepted “do not track” standards and systems, our Site does not respond to Do Not Track signals. In addition, we may allow third parties to collect personal information from your activity on our Site, as described in the “Information Collection and Use” section above and described in Annex 1.

California Shine The Light Disclosure Information

Although we do not disclose to any third-parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, email address, and the type of services provided to the customer, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (2) the names and addresses of all such third-parties.  We will respond to such written requests within 30 days following receipt at the email or mailing address specified below under “Contact Us”. If we receive your request at a different email or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received.  Please note that we are required to respond to each customer only once per calendar year.

Changes to This Privacy Policy

This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal data or use our Site, communicate with us via email or engage with our social media accounts. 

Contact For More Information

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at privacy@citizenrelations.com.

TEXAS CONSUMERS ONLY: Your Texas Privacy Rights

This Texas Notice provides additional information to Texas residents whose Personal Information is collected by us pursuant to Texas law, including the Texas Data Privacy and Security Act (“TDPSA”). If you are not a Texas resident, this Notice does not apply to you. Please visit our Privacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.

TDPSA RIGHTS

Right To Confirm

You have the right to know whether we are processing information about you. 

Right to Opt-Out of Selling, Targeted Advertising and Profiling

You have the right to opt-out of the sale of your Personal Information, the processing of your personal information for targeted advertising, and the use of your information for profiling purposes.

As defined under the TDPSA, we have not sold your Personal Information, have not engaged in profilinge, and have not shared your information for the purpose of targeted advertising. as defined under the TDPSA.

Right to Non-Discrimination For Exercising Consumer Privacy Rights

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the TDPSA. As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right.

Right to Correct

You have the right to request that we rectify inaccurate information about you.

Right to Request Deletion of Personal Data

You have the right to request the deletion of your personal data provided by or obtained about you, subject to certain exceptions permitted by law.

Right to Data Portability 

You can request a copy of your Personal Information in an easily accessible format and information explaining how that information is used.

HOW TO MAKE A RIGHTS REQUEST

You can make a Rights Request in the following ways: 

We will acknowledge your Request within 10 days and will attempt to respond substantively within 45-90 days.

You must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.

Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity. We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.

RIGHT TO APPEAL

You have the right to appeal our decision to deny any of your privacy rights requests above. Within 45 days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

You can make an appeal in the following ways:

We reserve the right to deny appeals in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

If your appeal is denied, you may submit a complaint to the Texas Attorney General at https://www.texasattorneygeneral.gov/consumer-protection.

Retention of Personal Informations

We will retain your Personal Information for as long as it is necessary for the purposes set out in the Privacy Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Contact for More Information

For information and questions about the use of your personal information or this Notice or your rights under Texas law, you may contact us at privacy@citizenrelations.com.

Changes To This Privacy Policy

This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.

See our full Privacy Policy here

See California Privacy Rights here

 

Annex 1: 
 

CATEGORY: Internet/Network Activity
 

  1. Examples
    IP address, your device information, domain name, geolocation, browsers you used to access our Site, webpages viewed, time spent on webpages, links clicks, transactions entered into and site-navigation patterns.
     
  2. Collected From 
    Your computer or mobile device, through your online activities and interactions with us, including, without limitation, your online activity on our Site, and on our social media channels or through our third-party sources. Third-party sources such as Google, publicly available data, other companies and referrals.
     
  3. Purposes 
    To better understand how you use our Site; to enhance, modify, or improve our Site, services, and general business; for other marketing, research, legal, and other business purposes; to comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.
     
  4. Disclosed To

    Consultants, service providers, and contractors that we use to support our business and operations (e.g. hosting or operating our Site and services, data collection, reporting, Site metrics and analytics, data analysis, fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services; Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; An acquirer or successor-in interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of Citizen or its affiliates including any negotiation thereof.

  5. Sold or shared
    No

  6. Retention period
    We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

 

CATEGORY: Business-to-Business (“B2B”) Information

  1. Exmaples
    Name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating the business relationship.
     
  2. Collected From
    You, if you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.
     
  3. Purposes
    For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.
     
  4. Disclosed To
    We do not disclose B2B Information outside our business relationship without your consent. 
     
  5. Sold or Shared
    No
  6. Retention period
    We will retain your B2B Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.