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C9 Staff’s Privacy Policy

This website collects some personal data from its users in order for it to provide its services, in order for it to meet its obligations in relation to said services, and in order for it to comply with applicable laws. 

Owner, Data Controller and Processor 

C9 Staff Inc.
5608 17th Ave. NW #766,
Seattle, WA 98107, USA 
Owner contact email: dpo@c9staff.com 


Data Collected 

This website, by itself or through third parties, collects: cookies; usage data; email address; phone number; unique device identifiers (for advertising and marketing purposes); first name; last name; company name; data communicated while using the service including ‘anonymous’ data such as IP address, geolocation, and website activity logs. 

Personal data may be freely provided by the user, or, in case of usage data, collected automatically when using this website. 

Unless specified otherwise, all data requested by this website is mandatory. Failure to provide this data may make it impossible for this website to provide its services. In cases where this website specifically states that some data is not mandatory, users are free not to communicate this data without consequences to the availability of services or the functioning of the website. 

Users who are unsure about which personal data is mandatory may contact the owner through the contact details provided herein. 

The use of cookies and/or other tracking tools by this website or by the owners of third-party services used by this website are for the purpose of providing the service required of and by the user. 

Users are responsible for any third-party personal data obtained, published or shared through this website and confirm that they have the third party’s consent to provide the data to the owner. 


Data Processing

Processing Methods
C9 Staff takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized use and management of the data. 

The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the data processing officer, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of this website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary. The list of people who may have access to this data may be requested from the owner at any time.

Legal Basis
The owner may process users’ personal data on the basis of one of the following:

  • users have given their consent for one or more specific purposes duly stated anywhere on this website whether by the owner or by duly authorized third parties. Note: Under some legislations the owner may be allowed to process personal data until the user objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of personal data is subject to European data protection law;
  • processing the data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
  • processing the data is necessary for the owner to comply with a legal obligation to which the same is subject;
  • processing the data is related to an obligation that is carried out in the public interest or in the exercise of official authority vested in the owner;
  • processing the data is necessary to pursue legitimate interests by the owner or by a third party.

In any case, the owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

Processing Location
The data is processed at C9 Staff’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the user’s location, data processing may involve transferring the user’s data to a country other than their own. 

Users are also entitled to learn about the legal basis of data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the owner to safeguard their data.

Users may, at any time, confer with the owner about the transfer of their data.

Data Retention 
Personal data shall be processed and stored for as long as required by the purpose they have been collected for. This means:

  • Personal data collected for purposes related to the performance of a contract between the owner and the user shall be retained until such contract has been fully performed.
  • Personal data collected for the purposes of the owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. 

The owner may be allowed to retain personal data for a longer period when consent for the same is given and as long as such consent is not withdrawn. Furthermore, the owner may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires or once consent is withdrawn, personal data shall be deleted. In such an event, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.


Purpose


The user’s data is collected to enable the owner to provide its service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its users or third parties), detect any malicious or fraudulent activity, as well as the following: 

  • analytics
  • tag management
  • managing contacts and sending messages
  • user database management
  • remarketing and behavioral targeting
  • advertising
  • interaction with external social networks and platforms
  • displaying content from external platforms
  • platform services
  • hosting and interaction with live chat platforms


The Rights of Users


Users may exercise certain rights regarding their data processed by the owner.

In particular, users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.
  • Object to processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their data. Users have the right to learn if data is being processed by the owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
  • Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, the owner will not process their data for any purpose other than storing it.
  • Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from the owner.
  • Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the user’s consent, on a contract which the user is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

GDPR Compliance
If you are located within the European Union, you are accorded additional data privacy protection by the General Data Protection Regulation (GDPR).

Under the GDPR, you have the right to:

  • The right to be informed – we must make it clear what data we are processing, why and who else may have access to said data.
  • The right of access – you have the right to see what data about you is held in our database.
  • The right to rectification – you have the right to get your data corrected or amended accordingly.
  • The right to erasure – under certain circumstances, you can ask for your personal data to be deleted from our database. This applies when the data is no longer required for the purpose it was collected for, if your consent for our collection and keeping of said data is withdrawn, or if there’s evidence that said data was acquired unlawfully.
  • The right to restrict processing – you have the right to ask us to temporarily stop processing your data. This applies when there’s a dispute or legal case that need to be concluded that affects the data or if said data is in the process of rectification.
  • The right to data portability – you have the right to request a copy of your data in a structured, commonly used, and machine-readable format.
  • The right to object – you have the right to object to further processing of your data if you deem such a process to be inconsistent with the primary purpose it was collected in the first place. These processes may include profiling, automation, and direct marketing.
  • Rights related to automated decision making and profiling – you have the right not to be subject to a decision based solely on automated processing.


How to exercise these rights
Any requests to exercise user rights can be directed to the owner through the contact details provided in this policy. 


Additional Information


In case of legal action
The user’s personal data may be used for legal purposes by the owner in court or in the stages leading to possible legal action arising from improper use of this application or the related services. 

The user declares to be aware that the owner may be required to reveal personal data upon request of public authorities in accordance with applicable laws. 

System logs and site maintenance
For operation and maintenance purposes, this website and any third-party services may collect files that record interaction with this website (system logs) use other personal data (such as the IP Address) for this purpose. 

Information not contained in this policy
More details concerning the collection or processing of personal data may be requested from the owner at any time. Please see the contact information at the beginning of this policy. 

“Do Not Track” requests
This website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies. 

Amendments
The owner reserves the right to make changes to this privacy policy at any time by notifying its users on this page and possibly within this website and/or – as far as technically and legally feasible – sending a notice to users via any contact information available to the owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. 

Should the changes affect processing activities performed on the basis of the user’s consent, the owner shall collect new consent from the user, where required. 

Legal information 
This privacy statement has been prepared based on provisions of multiple legislations, including the General Data Protection Regulation (GDPR), the California Consumer Protection Act (CCPA), and other similar legislation.

This privacy policy relates solely to this website unless otherwise stated.