ABOUT BOOKS CURRICULUM MUSIC OUTREACH SHOP Privacy Policy Effective Date: October 22, 2020 Welcome and Introduction The Information We Collect How We Use the Personal Information We Collect Disclosure of Personal Information to Third Parties Information You Make Publicly Available Transfers of your Personal Information Outside of the European Union Data Retention Your Rights Security Children’s Privacy Third Party Sites Governing Law Changes to Privacy Policy Contact Us Welcome and Introduction Welcome to David C Cook (including our divisions and affiliates, “we” or “us” or “our”). We operate a number of different websites. These include davidccook.org and integritymusic.com. This Privacy Policy describes how we collect, use, share, and safeguard personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. The Information We Collect We collect information which may identify you (“Personal Information”) when you visit our website, post on our bulletin boards, comment, use chat areas and any other personal data which you supply to us from time to time. The following provides examples of the type of information that we collect from you and how we use that information. Context Types of Data Primary Purpose for Collection and Use of Data Account Registration We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account. We have a legitimate interest in providing account related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history. Cookies and first party tracking We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Policy for more information. We have a legitimate interest in making our website operate efficiently. Cookies and Third Party Tracking We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our Cookie Policy for more information. We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics. Demographic Information We collect personal information, such as your age or location. We have a legitimate interest in understanding our users and providing tailored services. Distance Information When you use one of our Apps we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and your distance from a store that sells our products. We have a legitimate interest in understanding our users and providing tailored services. In some contexts our use is also based upon your consent to provide us with geo location information. Email Interconnectivity If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. We have a legitimate interest in understanding how you interact with our communications to you. Employment If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment. We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations. Feedback/Support If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. We have a legitimate interest in receiving, and acting upon, your feedback or issues. Mailing List When you sign up for one of our mailing lists we collect your email address or postal address. We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services. Order Placement We collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you place an order. We use your information to perform our contract to provide you with products or services. Partner & Affiliate Promotion We collect information that you provide as part of a co-branded promotion with another company. We have a legitimate interest in fulfilling our promotions. Surveys When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization. Website interactions We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. Web logs We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular. Special Categories of Personal Data – Information revealing religious beliefs Purpose of processing Legal basis of processing Tailor services or products Processing is based on your consent, and the information is optional to the service being requested Run surveys/polls/questionnaires Processing is based on consent Engage with any correspondence/communications received (including on the phone or via online chats) Processing is based on your consent, information is voluntarily provided Or Processing is in relation to a legal claim Analyze trends and use of content on our site Processing is based on consent Gather broad demographic information for use on an aggregated basis Processing is based on consent Certain services or products we offer may be tailored to a specific denomination. Also, as part of certain services on the site, we may ask you to identify your place of worship after you provide consent. You will, of course, have the option to decline to provide this information; however, if it is required for a particular service or product, you will be unable to obtain that service or product if you decline to provide it. In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check. How We Use the Personal Information We Collect In addition to the purposes and uses described above, we use information in the following ways: To identify you when you visit our websites or our online stores. To provide products and services or to process returns. To improve our services and product offerings. To streamline the checkout process. To conduct analytics. To respond to inquiries related to support, employment opportunities, or other requests. To send marketing materials that may relate to our products, services, sales, or promotions, or those of our partners. Our partners are other companies in our group, record labels, publishers, authors (or their agents), artists (or their agents) and/or our partner ministries. For internal administrative purposes, as well as to manage our relationships. Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete an online purchase we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business. Disclosure of Personal Information to Third Parties To help us provide you with superior service, timely completion of purchases and returns, as well as accurate shipments, we may share certain information relating to you within the David C Cook corporate family of entities, which we are part of. We may also share certain Personal Information with strategic, co-branded, or joint partners and with third party processors, service providers, and vendors, as necessary, to process your orders or requests and otherwise administer the account (however, we will only share credit or debit card information as required to effectively process your credit or debit card payment, or to analyze trends or usage of our website). These entities help us provide many important services to you, such as fulfilling and shipping orders, providing customer service and performing customer satisfaction surveys. We may also share information with third parties to verify information collected from you in order to protect against potential fraud, and we may receive Personal Information about you from these parties. Your election to opt-out of the data sharing within the “Your Rights” section is not an opt-out for the data sharing described in this paragraph. On occasion, we may be (or have a good faith belief that we are) required by law or litigation to disclose Personal Information pertaining to you. We may also disclose such information if we determine that for national security, law enforcement, or other issues of public importance or safety, disclosure is necessary. At times, we may share Personal Information in aggregate, so that no one individual can be identified (i.e., anonymous). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage. We may also have to share information in the event of a bankruptcy proceeding. We may also ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy. Information You Make Publicly Available You should be aware that information (including your name, email address, address, or phone number) provided by you in a posting on the website or any public page, bulletin board or social media site or function is available (even after you stop participating on the website) to any other individual who has access to that same website and may be used by another individual in a manner unintended by you, including as a target for unsolicited communications. You should therefore treat any information provided by you in the content of a submission or post to the website as public information. For this reason, we urge you to act cautiously in providing any such information in your submissions or posts, as we are not liable for any use or misuse by an individual user of the information you provide in a submission or post. Transfers of your Personal Information Outside of the European Union If you choose to provide us with Personal Information, you consent to the processing of that information in other countries outside of the EU, including the United States. Your Personal Information is transferred subject to appropriate safeguards, in the form of an agreement including the model contract clauses prescribed by the European Commission. You have the right to request a copy of this agreement by contacting us on the details set out below. Please note, we reserve the right to redact elements for commercial sensitivity. The other third party providers that we use to operate this website, located outside of the EU, and which may receive your Personal Information are under safeguards set out by the EU, of an adequacy decision by the Commission. For more information, visit: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. Data Retention We only keep your information for as long as necessary in relation to the purpose for which we are processing that information. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We maintain a data retention policy which we apply to all data in our care. Where your personal information is no longer required we will ensure it is securely deleted. Your Rights Where required by law and depending on your residence, you may have certain rights and can make the following choices regarding your personal information. Access to Your Personal Information. If you are in the EU, you may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Changes to Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law. Deletion of Your Personal Information. If you are in the EU, you may request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Objection to Certain Processing. If you are in the EU, you may object to our use or disclosure of your personal information by contacting us at the address described below. Information Portability. If you are in the EU, you may request that we transfer your Personal Information to a third party in a standardized machine-readable format. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive, or updating your preferences here. If you decide not to receive promotional emails, we may still send you service related communications. Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us at the email address provided below with “NO PROMOTIONAL MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed. Promotional Text Messages.If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.” Revocation of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below. Your California Privacy Rights. Under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family, or household use are entitled to request and obtain once a calendar year information from us about the Personal Information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared such information for the immediately prior calendar year (e.g., requests made in 2015 will receive information regarding 2014 sharing activities). To obtain this information, please send an email message to the address provided below with “Request for California Privacy Information” in the subject line and in the body of your message. The requested information, if required by law, will be provided to you at your email inbox. Security We use reasonable and appropriate efforts to secure Personal Information once we receive it, and to help prevent it from being disclosed to individuals who are not described in this policy. Unfortunately, no security system can be guaranteed to be 100% secure. Accordingly, we cannot guarantee the security of your information and cannot assume liability for improper access to it. In the event that we are required by law to inform you of any unauthorized access to your Personal information, we may notify you electronically, in Writing, or by telephone, if permitted to do so by law. By using any service we provide, including our website and user interfaces, or providing information to us through any means, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of any such service or our website. Children’s Privacy Our site is not directed to children and we do not knowingly collect or maintain information on children under the age of 16. If you are under the age of 16, please do not submit Personal Information to us. If you are the parent or guardian of a child age 16 or under who has provided us with Personal Information and you would like that information removed, please contact us via the details provided below. Third Party Sites This Privacy Policy applies only to this website. Other websites we own and websites owned or operated by third parties may contain different privacy policies and practices. This Privacy Policy does not apply to any other person, entity, organization, or website to or from which the website links or is linked. You are strongly encouraged to read and regularly review posted privacy policies on all websites, whether or not owned by us or affiliated with the site. Governing Law This Privacy Policy applies to all visitors in the United States and to visitors from outside the United States to the extent allowed by applicable law. This site and the servers upon which it is hosted are located in the United States. This site is governed by the laws of the State of Colorado in the United States. The law governing this website and any disputes arising out of a visit to this website, including privacy, shall be governed by Colorado law. Changes to Privacy Policy We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. We will note the effective date of the latest version at the beginning of the Privacy Policy. Contact Us If you have any questions, comments, or complaints concerning our privacy practices please contact our data protection officer at the appropriate address below. Unless otherwise noted, you can also reach out to us at this email address to exercise your rights listed in this Privacy Policy. We will attempt to respond to your requests and to provide you with additional privacy-related information. privacy@davidccook.com 4050 Lee Vance Dr. Colorado Springs, CO 80918. If you are an EU or UK resident are not satisfied with our use of your Personal Information or our response to any request by you to exercise your data protection rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the authority that supervises our processing of your Personal Information. 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