Customer Solutions Group Privacy Policy
Last updated: January 5, 2024
We are Call Center Management, Inc. dba Customer Solutions Group (“CSG”). This Privacy Policy describes how we protect your data and respect your privacy. We are strongly committed to keeping secure any information we obtain from you or about you. Any questions or concerns with respect to your data or privacy should be directed to privacy@warm-transfer.com.
1. APPLICABILITY OF THIS PRIVACY POLICY
This Privacy Policy applies to CSG’s websites (including, without limitation, https://warm-transfer.com/) (the “Websites”), telephone calls, text messaging, and any other services provided by CSG (collectively, the “Services”), and any other interactions (e.g., sales inquiries, customer support, etc.) you may have with CSG.
In connection with the Services, you may be referred to or connected with representatives of third party products, services, or businesses (“Third Party Services”). While using the Websites, you may be directed to a third party website via links or other references, which may take you to that third party website (“Third Party Websites”). This Privacy Policy does not apply to any data collected from you or about you by Third Party Services or Third Party Websites. Third Party Services and Third Party Websites are not owned or controlled by CSG and may have their own privacy policies and practices. You should review such Third Party Services’ or Third Party Websites’ privacy policy (and such other terms and conditions) to determine how your data will be used before sharing any Personal Information.
2. NOTICE TO CLIENTS, CONSUMERS, AND VISITORS
BY VISITING OR ACCESSING THE WEBSITES, PROCURING OR RECEIVING THE SERVICES, OR INTERACTING WITH ANY ASPECT OF OUR BUSINESS, YOU ACCEPT THE TERMS OF THIS PRIVACY POLICY AND EXPRESSLY CONSENT TO OUR COLLECTION, USE, AND DISCLOSURE OF DATA, INCLUDING YOUR PERSONAL INFORMATION, PROVIDED TO OR OTHERWISE RECEIVED BY US FOR THE PURPOSES AND IN THE MANNER DESCRIBED IN THIS PRIVACY POLICY AND THE APPLICABLE CLIENT AGREEMENT.
A separate agreement governs the provision of the Services (the “Client Agreement”), including the processing of any data, including Personal Information, provided by the Client to CSG or obtained by CSG on behalf of the Client in connection with the Services (“Client Data”). The organization that entered into the Client Agreement (the “Client”) procures the Services from CSG and controls any associated Client Data. The “Client” includes individuals who have been authorized by the Client to act on behalf of the Client in connection with the Services. CSG provides the Services solely on behalf of Clients. Your receipt of the Services may be subject to the Client’s policies, if any. If you have any questions about the Client’s privacy practices, please contact the applicable Client pertaining to the Services you received. CSG is not responsible for the privacy or security practices of our Clients, which may differ from those set forth in this Privacy Policy.
3. DATA WE COLLECT AND RECEIVE
CSG may receive, collect, process, store, access, and disclose information that alone or in combination with other information in our possession could be used to identify you, which is protected as “personal information” or “personal data” under applicable privacy and data protection laws (“Personal Information”). You acknowledge and agree we may receive, collect, process, store, access, and disclose your Personal Information to facilitate the provision of the Services in the manner described in this Privacy Policy and the applicable Client Agreement.
3.1 Client Data. The Client may provide CSG certain Client Data, including Personal Information, in connection with the Services. Client Data is governed by the applicable Client Agreement. Client Data may include Lead Data, Data Enhancements, or any Client Data otherwise defined in the applicable Client Agreement. If you have any questions about your Personal Information with respect to Client Data, please contact the applicable Client.
3.1.1 Lead Data. The Client may provide CSG with Personal Information about you as a suitable candidate for the Client’s products or services to identify, contact, and communicate with you as necessary to provide the Services to the Client (collectively “Lead Data”). Lead Data may include your name, telephone number, state of residence, zip code of residence, and other information that CSG may use to qualify the Client’s prospective customers. The Client is solely responsible for ensuring it is authorized to share your Personal Information with us for any purpose.
3.1.2 Data Enhancements. When you interact with the Services, we may obtain other Personal Information from you or about you via telephone, text messaging, or other channels of communication as necessary to provide the Services to the Client (collectively, “Data Enhancements”). Data Enhancements may contain Personal Information to the extent you voluntarily disclose Personal Information in connection with the Services.
3.2 Other Information. CSG may collect Other Information from you or about you in connection with the Websites, the Services, and interactions with CSG. Other Information may include Metadata, Third Party Services, and Communication Information. If you have any questions about your Personal Information with respect to Other Information, please contact CSG at privacy@warm-transfer.com.
3.2.1 Metadata. When you interact with the Services, metadata may be generated that provides additional context about your receipt of the Services (“Metadata”).
3.2.2 Third Party Services. Third Party Services may be integrated with or made available in connection with the Services. Third Party Services may share certain data with CSG to effectuate the integration or offering. You should check the privacy settings and notices of these Third Party Services to understand what data may be disclosed to CSG.
3.2.3 Communication Information. CSG receives data, including Personal Information, when submitted on or through the Websites or if you contact us (e.g., by email, telephone, written correspondence, web based forms, or otherwise), request support, apply for or take a job with us, contract with us, or otherwise communicate with us (collectively, “Communication Information”).
3.3 No Cookies. CSG does not use cookies or similar tracking technologies on the Websites or in connection with the Services. To learn more about cookies, please visit https://allaboutcookies.org/.
3.4 No Sensitive Personal Information. CSG does not intentionally collect, process, or store any Sensitive Personal Information in connection with the Services. We also request that Clients do not provide any Sensitive Personal Information in Client Data and that you do not volunteer any Sensitive Personal Information in your interactions with CSG in connection with the Services. “Sensitive Personal Information” includes, but is not limited to, government-issued identification numbers; financial account numbers; credit or debit card numbers; any code or password that could be used to gain access to personal accounts; genetic data; biometric data; information about racial or ethnic origin, citizenship or immigration status, political opinions, religious or philosophical beliefs, or trade union membership; or information concerning health, sex life, or sexual orientation. CSG is not responsible and will not be liable for any loss or damages you or another individual may experience due to your unsolicited disclosure of Sensitive Personal Information in connection with the Services.
3.5 No Children’s Data. The Services are not directed to or intended for children without parental or guardian consent. CSG does not intentionally collect, process, or store any Personal Information from any person under 13 years of age without verifiable parental consent. In the event we discover we have inadvertently collected, processed, or stored any Personal Information from a person under 13 years of age, we will promptly take the appropriate steps to delete such data or seek the necessary verifiable parental consent for that collection in compliance with the Children’s Online Privacy Protection Act (“COPPA”) or applicable law.
4. HOW AND WHY WE USE DATA
Client Data will be used by CSG in accordance with the terms of the applicable Client Agreement, the Client’s instructions, and as otherwise required by applicable law.
Other Information will be used by CSG to perform the Services and related support for the Services, in furtherance of our legitimate interests in operating our business and providing the Services, or pursuant to your express consent for a specific purpose. Specifically, CSG may use Other Information for these purposes and legal bases:
Providing the Websites and Services. To make the Websites available and render the Services under the applicable Client Agreement.
Improving the Websites and Services. To improve and optimize the Websites and Services, such as to monitor and analyze usage, service performance, security, and technical issues.
Support Services. To respond to support requests and otherwise provide support for and resolve problems with the Services.
Communications. To send administrative, sales, and marketing emails, text messages, telephone calls, and other communications. Service-related communications are essential to delivery of the Services and you cannot opt-out. Marketing communications, if any, are optional and you may opt-out at any time by following the instructions in any such communication or by contacting us at privacy@warm-transfer.com.
Account Management. To contact for billing, account management, feedback, and other administrative matters.
Security Purposes. To maintain adequate security and help prevent and investigate security issues and abuse.
Legal Obligations. To perform contractual obligations and comply with legal obligations as required by applicable law, legal process, or regulations.
5. HOW WE SHARE AND DISCLOSE DATA
Except as described in this Privacy Policy or the applicable Client Agreement, CSG will not disclose your Personal Information for any purpose other than to the extent necessary to perform the Services and related support for the Services, unless you expressly consent to any other disclosure. CSG may share and disclose data with respect to:
Client’s Instructions. CSG may share and disclose Client Data, including Personal Information, in accordance with the Client’s instructions, including the applicable Client Agreement, and as required by applicable law. Subject to the applicable Client Agreement, Client Data is generally treated as the confidential information of the Client unless stated otherwise.
Client Access. The Client and the Client’s representatives and personnel may have access to your data, including Personal Information, in connection with the Services rendered under the applicable Client Agreement.
Rendering the Services. CSG employees and contractors may have access to your data, including Personal Information, on a need to know and confidential basis to the extent necessary to render the Services and related support for the Services.
Third Party Service Providers. CSG engages third parties in connection with the provision of the Services (“Third Party Service Providers”). CSG may share your data, including Personal Information, with Third Party Service Providers (e.g., email services, platform hosting, cloud computing services, data storage and processing facilities, telecommunication networks, telephony service providers, etc.) to the limited extent necessary to let them perform business functions and services for us or on our behalf in connection with the provision of the Services; provided that such Third Party Service Providers process data in a manner consistent with this Privacy Policy and applicable privacy and data protection laws and will not use or disclose Personal Information for any other purpose.
Third Party Services. CSG may share your data, including Personal Information, with Third Party Services as necessary to provide the Services to the Client. Third Parties Services may have their own privacy policies and practices. You should review the applicable Third Party Services’ privacy policy (and such other terms and conditions) to determine how your data will be used before sharing any Personal Information.
Changes to Business. If CSG engages in a merger, acquisition, sale of some or all of its assets or stock, financing, public offering of securities, reorganization, bankruptcy, dissolution, or similar transaction or proceeding, or steps in contemplation of such activities (e.g., due diligence), CSG may share or disclose your data, including Personal Information, in connection therewith, subject to standard confidentiality obligations.
Aggregated or De-identified Data. If any data is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use or disclose such aggregated or de-identified data for any purpose.
Enforcement of Agreements. CSG may disclose data to ensure compliance with and enforce the applicable Client Agreement and any other contractual or legal obligations with respect to the Services and our business.
Protection of Rights. CSG may disclose data to protect and defend our rights and property, including intellectual property rights, and to ensure compliance with applicable laws and enforce third party rights, including intellectual property and privacy rights.
Legal Compliance. If we are compelled by law, such as to comply with a subpoena, court order, or other lawful process, or in response to a lawful request by public authorities to meet national security or law enforcement requirements, CSG may disclose data if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.
Safety and Security. CSG may disclose data to protect your safety and security; to protect the safety, security, and property of the Client; or to protect the safety, security, and property of CSG and our employees, contractors, agents, and representatives.
Your Consent. CSG may disclose your data to third parties when we have your express consent to do so.
6. RETENTION
CSG will retain Client Data in accordance with the terms of the applicable Client Agreement and as otherwise permitted by applicable law. CSG may retain Other Information and any other data pertaining to you, including Personal Information, for as long as necessary for the purposes described in this Privacy Policy, including for the period of time needed to pursue our legitimate business interests, such as providing the Client with the Services, conducting audits, resolving disputes, complying with contractual obligations (including but not limited to the applicable Client Agreement), and complying with (and demonstrating compliance with) legal obligations. Notwithstanding the foregoing, CSG generally retains Personal Information for 120 days after its intended use in connection with the Services and securely deletes all applicable Personal Information stored electronically after the retention period has expired. CSG may securely retain data, including Personal Information, on physical offline media for a longer retention period as required or permitted by applicable laws for legal, auditing, or compliance purposes.
7. SECURITY MEASURES
CSG maintains commercially reasonable administrative, technical, and physical security measures to safeguard Personal Information both online and offline from loss, misuse, and unauthorized access, use, disclosure, modification, or destruction. However, no internet or data transmission is completely secure or error-free, and we cannot guarantee that unauthorized access, hacking, data losses, or other breaches will never occur. You provide Personal Information at your own risk. Therefore, careful consideration should be given when deciding what information you provide to the Client or CSG in connection with the Services. CSG is not responsible for circumvention of any security measures in connection with the Services. If you believe your privacy has been breached, please contact us immediately at privacy@warm-transfer.com.
8. LOCATION OF PROCESSING
CSG is established and solely operates in the United States. You understand and acknowledge that your Personal Information will be processed in the United States and, if applicable, transferred from your location to our facilities and servers in the United States.
9. INDENTIFYING THE CONTROLLER AND PROCESSOR
Privacy and data protection laws in certain jurisdictions differentiate between the “controller” or “business” and “processor” or “service provider” with respect to the processing of Personal Information. In general, the Client is the controller and business with respect to Client Data. In general, CSG is the processor and service provider with respect to Client Data and the controller and business with respect to Other Information.
10. YOUR RIGHTS
Depending on location, individuals in certain U.S. states and various countries across the globe may have certain statutory rights in relation to their Personal Information. For example, subject to any exemptions provided by applicable law, you may have the right to exercise your rights and request certain actions with respect to your Personal Information, such as to:
Access your Personal Information.
Delete your Personal Information.
Correct or update your Personal Information.
Transfer your Personal Information elsewhere.
Withdraw your consent to the processing of your Personal Information where we rely on consent as the legal basis for processing.
Object to or restrict the processing of your Personal Information where we rely on legitimate interests as the legal basis for processing.
CSG endeavors to comply with all applicable privacy and data protection laws. Please direct any requests to exercise your rights under applicable privacy and data protection laws to the applicable Client. For any other requests related to your rights under applicable privacy and data protection laws, please contact us at privacy@warm-transfer.com. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
11. STATE SPECIFIC PRIVACY LAWS
State laws, including the California Consumer Privacy Act (“CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), and the Utah Consumer Privacy Act (“UCPA”) provide specific rights to consumers within those states with respect to the Personal Information a covered business or controller collects from such consumers. This may include rights to (1) request access to the Personal Information we collect about you and (2) request deletion or correction of such Personal Information. These state laws do not apply to CSG directly at this time; however, they may apply to the applicable Client to whom we provide Services. As we obtain Personal Information from the Client or from you on behalf of the Client, we may be asked to assist the Client with responding to access and deletion requests under these state laws, as applicable.
11.1 California – CCPA Applicability
Pursuant to the applicable Client Agreement with the Client, we act as a “service provider,” as defined under the CCPA, for all Clients who retain our Services. We do not use any Personal Information we collect through our Services for any purposes not included in our agreements.
11.1.1 For Deletion Requests. With respect to data collected by service providers, the CCPA provides specific exceptions to deletion requests, including where data is maintained by a “business or a service provider” in order “to enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.” Cal. Civ. Code § 1798.105. Because we collect Personal Information from you or about you on behalf of and at the direction of the Client for the sole purpose of serving the Client and we do not use the data for any purposes outside of the Services under the Client Agreement, we are exempt from deletion requests under the CCPA.
11.1.2 For Data Access Requests. If the Client receives a data access request from a California consumer and determines that we may have relevant data, the Client may make a direct request to us to assist with the request. We will endeavor to provide the Client with a response to any such request within 30 days of our receipt of the request.
11.1.3 For Correction Requests. If the Client receives a correction request from a California consumer and determines that, we may have relevant data, the Client may make a direct request to us to assist with any correction to the data necessary. We will endeavor to provide the Client with a response to any such request within 30 days of our receipt of the request.
11.2 California – “Shine the Light” Notice
CSG does not disclose Personal Information to third parties for any third parties’ direct marketing purposes, other than the Client which originates such Personal Information, and will not do so unless you affirmatively consent to such disclosure. Since CSG provides its California users with notice of its rights as described above, pursuant to Cal. Civ. Code § 1798.83(c)(2), CSG complies with California’s “Shine the Light” law and is not obligated to provide California users with the names and addresses of all the third parties that received Personal Information from CSG for the third parties’ direct marketing purposes during the preceding calendar year.
11.3 Virginia – VCDPA Applicability
Pursuant to the applicable Client Agreement with the Client, we act as a “processor,” as defined under the VCDPA, for all Clients who retain our Services. We do not use any Personal Information we collect through our Services for any purposes not included in our agreements.
11.3.1 For Deletion and Correction Requests. The VCDPA does not limit a processor’s ability to collect, use, or retain data to: “Perform internal operations that are reasonably aligned with the expectations of the consumer or reasonably anticipated based on the consumer’s existing relationship with the controller or are otherwise compatible with processing data in furtherance of the provision of a product or service specifically requested by a consumer or the performance of a contract to which the consumer is a party.” Va. Code Ann. § 59.1-582. Because we collect Personal Information from you or about you on behalf of and at the direction of the Client for the sole purpose of providing Services to the Client and we do not use the data for any purposes outside of the Services under the Client Agreement, we are exempt from deletion and correction requests under the VCDPA.
11.3.2 For Data Access Requests. If a Client receives a data access request from a Virginia consumer and determines that we may have relevant data, the Client may make a direct request to us to assist with the request. We will endeavor to provide the Client with a response to any such request within 30 days of our receipt of the request.
11.4 Colorado – CPA Applicability
Pursuant to the applicable Client Agreement with the Client, we act as a “processor,” as defined under the CPA, for all Clients who retain our Services. We do not use any Personal Information we collect through our Services for any purposes not included in our agreements.
11.4.1 For Deletion and Correction Requests. The CPA does not restrict a processor’s ability to: “perform internal operations that are reasonably aligned with the expectations of the consumer based on the consumer’s existing relationship with the controller.” C.R.S. § 6-1-1304 et seq. Because we collect Personal Information from you or about you on behalf of and at the direction of the Client for the sole purpose of providing Services to the Client and we do not use the data for any purposes outside of the Services under the Client Agreement, we are exempt from deletion and correction requests under the CPA.
11.4.2 For Data Access Requests. If a Client receives a data access request from a Colorado consumer and determines that we may have relevant data, the Client may make a direct request to us to assist with the request. We will endeavor to provide the Client with a response to any such request within 30 days of our receipt of the request.
11.5 Connecticut – CTDPA Applicability
Pursuant to the applicable Client Agreement with the Client, we act as a “processor,” as defined under the CTDPA, for all Clients who retain our Services. We do not use any Personal Information we collect through our Services for any purposes not included in our agreements.
11.5.1 For Deletion and Correction Requests. The CTDPA does not limit a processor’s ability to collect, use, or retain data to: “Perform internal operations that are reasonably aligned with the expectations of the consumer or reasonably anticipated based on the consumer’s existing relationship with the controller or are otherwise compatible with processing data in furtherance of the provision of a product or service specifically requested by a consumer or the performance of a contract to which the consumer is a party.” CTDPA § 10 (b)(4). Because we collect Personal Information from you or about you on behalf of and at the direction of the Client for the sole purpose of providing Services to the Client and we do not use the data for any purposes outside of the Services under the Client Agreement, we are exempt from deletion and correction requests under the CTDPA.
11.5.2 For Data Access Requests. If a Client receives a data access request from a Connecticut consumer and determines that, we may have relevant data, the Client may make a direct request to us to assist with the request. We will endeavor to provide the Client with a response to any such request within 30 days of our receipt of the request.
11.6 Utah – UCPA Applicability
Pursuant to the applicable Client Agreement with the Client, we act as a “processor,” as defined under the UCPA, for all Clients who retain our Services. We do not use any Personal Information we collect through our Services for any purposes not included in our agreements.
11.6.1 For Deletion and Correction Requests. The UCPA does not limit a processor’s ability to process Personal Information to perform an internal operation that is: “(i) reasonably aligned with the consumer’s expectations based on the consumer’s existing relationships with the controller; or (ii) otherwise compatible with processing to aid the controller or processor in providing a product or service specifically requested by a consumer or a parent or legal guardian of a child or the performance of a contract to which the consumer or a parent or legal guardian of a child is a party.” UCPA § 13-61-304(1)(m). Because we collect Personal Information from you or about you on behalf of and at the direction of the Client for the sole purpose of providing Services to the Client and we do not use the data for any purposes outside of the Services under the Client Agreement, we are exempt from deletion and correction requests under the UCPA.
11.6.2 For Data Access Requests. If a Client receives a data access request from a Utah consumer and determines that we may have relevant data, the Client may make a direct request to us to assist with the request. We will endeavor to provide the Client with a response to any such request within 30 days of our receipt of the request.
12. ENFORCEMENT
CSG will actively monitor its relevant privacy and security practices to verify adherence to this Privacy Policy. Any agents, contractors, service providers, or other third parties subject to this Privacy Policy that CSG determines is in violation of this Privacy Policy or applicable privacy and data protection laws will be subject to disciplinary action up to and including termination of such services. If you believe there has been a violation of this Privacy Policy or applicable privacy and data protection laws, please contact us immediately at privacy@warm-transfer.com.
13. CHANGES TO THIS PRIVACY POLICY
CSG may change, modify, or update this Privacy Policy from time to time, in whole or in part, in CSG’s sole discretion. We encourage you to visit this page at https://warm-transfer.com/privacy to stay informed about our privacy practices and review our most current Privacy Policy. Any changes, modifications, or updates to this Privacy Policy will become effective immediately upon such posting unless stated otherwise. By continuing to use the Services or providing us with Personal Information after we have posted an updated Privacy Policy or notified you by other means, you consent to be bound by such changes to this Privacy Policy.
14. CONTACT US
We encourage you to contact us with any questions, complaints, or requests with respect to your Personal Information or this Privacy Policy.
You may contact us at: privacy@warm-transfer.com
Customer Solutions Group
Attn: Privacy
280 South Beverly Drive, Suite 416
Beverly Hills, CA 90212
USA
