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Coto Global Solutions
Family of Companies
Privacy Policy
All the members of the Coto Global Solutions family of companies, consisting of COTO GLOBAL SOLUTIONS, LLC, TELE-INTERPRETERS LLC, COTO-LANGUAGE SERVICES, LLC, and LINGO SYSTEMS, LLC, are committed to protecting your privacy. This privacy policy and agreement ("Privacy Policy") covers how we collect, use, and treat personal information that you may provide through our website (the "Website" or the "Site") or you may provide over the telephone. The terms “you” and “your” in this Privacy Policy refer to any visitor to our Website, including (i) casual visitors to our Site ("Site Visitors"), (ii) interpreters and translators who may apply for employment or submit other information through our Site ("Interpreters"), and (iii) our clients and prospective clients, who may submit business contact information and other information via our Site ("Clients" and "Prospective Clients"). The terms "Coto Global", “we” and “us” refer to all the members of the Coto Global Solutions family of companies.
1. Your Consent
Please read this Privacy Policy carefully; once you consent to this Policy's terms, it creates legal obligations on you and on Coto Global. You will show your consent to the terms of this Privacy Policy in different ways, depending on your relationship to the Site. If you do not agree with the terms of this Privacy Policy, please refrain from using our Site. The procedures for consenting to this Policy are (a) less formal if you are simply a casual Site Visitor, and (b) more formal if you are an Interpreter or a Client or Prospective Client, affirmatively submitting information to us through the Site.
1.1. Consent by Site Visitors. If you access and use our Website as a Site Visitor, you are acknowledging that you have read and understood this Privacy Policy, and agree to be legally bound by it.
1.2. Consent by Clients, Prospective Clients, and Interpreters. If you submit information directly through our Site by using, for example, an online profile form, you will be prompted to click an "I Accept" button linked to this Policy when you submit the information. Clicking "I accept" confirms your agreement to be bound by this Privacy Policy. For other information, your access and use of our Website acknowledges that you have read and understood this Privacy Policy, and agree to be legally bound by it.
2. Scope of Policy
This Privacy Policy applies to (i) any anonymous information you provide to us online while visiting or using our Site, (ii) personally identifiable information you may provide to us through the Website, and (iii) personally identifiable information you provide to us over the telephone. This Privacy Policy does not apply to the content of communications translated by our companies. ("Translated Communications"). We strictly protect the confidentiality of Translated Communications, however the terms and conditions of that commitment are located in our formal contracts with Clients, not in this Privacy Policy.
3. The Information We Collect, and Our Uses Of This Information
We will not share with any third party personally identifiable information you may provide via the Website or telephone, other than as expressly disclosed in this policy. By "personally identifiable information" we mean information that identifies you, such as your name, mailing address, email address, telephone number, or credit card information.
We may collect information at different points on our Website, and if we do, we will use this information as follows:
3.1. Account Sign-Up. If, in order to sign up for an account via our Website, we require that you complete a Client Profile Form, the form will ask for contact information, which includes such items as (i) name; (ii) organization; (iii) title; (iv) business phone; and (v) email address. We will use the information from this Profile Form to establish accounts for our Clients, and to assist in processing billings. In addition, our system may rely on this information in part to track account data for our Clients, and to increase the efficiency of our responses to Client translation requests.
3.2. Employment Applicants. Our Web Site may ask Interpreters to submit employment applications to us. We would use the information we receive from these Interpreters (i) to process the Interpreters' employment applications, (ii) to contact references which may be identified in the applications, (iii) to collect and compile additional information concerning the Interpreter from available sources, consistent with applicable law, and (iv) to evaluate the Interpreter's candidacy for employment.
3.3. Processing Transactions and Requests. We would use contact information and other information that Clients and Prospective Clients may provide to us for purposes of processing their requests and orders, and fulfilling their interpreting needs. In each of these instances, we use the information you provide to us strictly for the purposes for which you submit the information.
3.4. Informational Notices and Bulletins. Periodically, we may choose to send news, bulletins, marketing materials, or other information to you, and will use personally identifiable information to send such communications. If we choose to undertake such communications, you will have the ability to opt out of receiving these communications as provided in Section 6.
3.5. Referral Sources. If you are referred to us, we may use your name and/or your company's name in a "thank-you" communication to the referral source. We will not use more identifying information than is necessary in our communication to the referral source.
3.6. Aggregate Information. “Aggregate Information” is anonymous information that does not identify you, and may include statistical information concerning your use of our services, or the pages on our Site that you visit most frequently. We use Aggregate Information to analyze the effectiveness of our Site, to improve and tailor our services, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our services and the characteristics of visitors at our Site, and may share Aggregate Information with third parties. Rest assured, though, that Aggregate Information provided to third parties will not allow anyone to identify you, or determine anything personal about you. We may collect Aggregate Information through features of the software that supports our services, through cookies, and through other means described below.
3.7. IP Addresses. Coto Global may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer's name, the type and version of your web browser, referrer addresses and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used. None of this data contains personally identifiable information.
3.8. Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies and other similar technologies on our Website, and may use them to recognize you when you return to our Website. You may set your browser so that it does not accept cookies.
3.9. Computer Configuration. In order to determine whether your computer is supported by our system, we may collect certain anonymous information. This information includes, but may not be limited to, your operating system and browser, as well as the presence of any software that our Website may require to operate with your computer, or other third party software on your computer. This information is kept strictly confidential and is not shared with third parties, except as provided for in this Privacy Policy.
3.10. Extent of Information Collected. Coto Global does not collect any more personal information than reasonably necessary to provide our services.
4. No Obligation to Consider Employment Applications.
Due to the nature of the Internet and the structure of our Website, we may receive (i) substantially more applications through the Website than we are able or wish to review, (ii) applications which do not meet the requirements for positions that are available, and (iii) applications at points where no positions are currently available. Accordingly, there is no assurance that Coto Global will process or review materials that an Interpreter submits seeking employment with Coto Global, and Coto Global expressly disclaims any obligation to engage in such processing or review, and disclaims any obligation to respond to any Interpreter submissions.
5. We Do Not Disclose Information to Unaffiliated Third Parties; Limited Exceptions
We will not disclose your personally identifiable information to unaffiliated third parties without your express consent, except in the following limited circumstances:
5.1. Our Site Vendors. We may employ other companies to perform functions on our behalf, such as maintaining the Website, providing services related to the Site, collecting information, responding to and sending electronic mail, or other functions necessary to our business. We may need to share your personally identifiable information with these companies (collectively, "Site Vendors"). We will provide Site Vendors with only that information necessary to perform their functions, and we will not allow them to use your personally identifiable information for any other purpose.
5.2. Imminent Harm. We may reveal your personally identifiable information to attorneys, private investigator organizations or law enforcement agencies if we believe (a) that you are in risk of harm from another, or (b) that you are harming or interfering (or will imminently harm or interfere) with others or violating (either intentionally or unintentionally) our Terms and Conditions of Use or otherwise violating legal rights.
5.3. Legal. Coto Global will reveal your personally identifiable information, to the extent we reasonably believe we are required to do so by law, or to the extent needed to enforce contractual obligations between us. If we receive legal process calling for the disclosure of your personally identifiable information we will attempt to notify you via any email address you may have supplied to us through the website within a reasonable amount of time before we respond to the request, unless such notification is not permitted.
5.4. Transfer of Site. Coto Global shall be entitled to transfer to a third party information it collects, including any personally identifiable information, in connection with a sale of all or substantially all of the assets of any of the members of the Coto Global family of businesses, provided the acquiring third party has agreed to safeguard your personally identifiable information with protections that in all material respects are the same as or more protective than those set out in this Privacy Policy.
6. Changing or Removing Information; Opting Out
6.1. Discretionary Account Information. To allow appropriate control over personally identifiable information, if you submit information to us through this Website, and we create an account for you including that information, we will provide you with access to your account or a procedure to change or update discretionary information that you have previously submitted.
6.2. Opt-Out. If we choose to send to you bulletins, updates, or other unsolicited communications that are marketing-related materials, we will provide you with the ability to decline -- or “opt-out of” – receiving such communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. Please understand that you will not be allowed to "opt–out" of formal notices concerning operation of this Website, and legal and other related notices concerning your relationship to the Site.
6.3. Deleting Information. Finally, if you request, we will remove your name and all other personally identifiable information from our databases. Please understand, however, that it may be impossible to remove this information completely, due to backups and records of deletions. In addition, please understand that, if you request deletion of your information, you will be unable to utilize associated features of our services. You may not remove de-identified or aggregate data from our databases.
7. Security
We have put in place security systems designed to prevent unauthorized access to or disclosure of information you may provide to us through the Website, and we take all reasonable steps to secure and safeguard this information. We store all personally identifiable information we receive on a separate system, designed to be secure and isolated from direct connection to the Internet. Coto Global employees (and employees of our Site Vendors) are required to acknowledge that they understand and will abide by our policies with respect to the confidentiality of personally identifiable information. Moreover, we provide access to our databases containing personally identifiable information on a need-to-know basis only.
Our security systems are therefore structured to deter and prevent hackers and others from accessing information you provide to us. We also use software programs to monitor network traffic, to identify unauthorized attempts to upload or change information, or otherwise cause damage. Please understand, though, that this information should not be viewed to warrant as fail-proof the security of information provided by or submitted to Coto Global. Due to the nature of Internet communications and evolving technologies, we cannot provide, and disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
8. Notice of Security Incident
If we detect, despite the safeguards set out above, an intrusion or other unauthorized access to or use of personally identifiable information (an "Intrusion"), we will (i) notify effected users of the Intrusion if the information at issue is sensitive, in our discretion, (ii) deliver this notice by the means we deem most efficient under the circumstances (such as, for example, first class mail or email); (iii) use contact information for each effected user that is current in our files; and (iv) use commercially reasonable efforts to accomplish these steps and effect this notice in a timely manner. To the extent applicable law requires steps in addition to those specified above, we will under all circumstances comply with applicable law.
9. Notification of Changes
From time to time, Coto Global may change its Privacy Policy. If we make any changes regarding disclosure of personally identifiable information to third parties, we may attempt to contact you prior to the date the modified policy is scheduled to take effect. We will post notice of the new or revised Policy from the privacy link on our Website. Your use of our Site following any such change constitutes your agreement to follow and be bound by the Privacy Policy, as changed.
10. Privacy Protection For Children.
Our Website is not directed at children, and we will not accept or request personally identifiable information from individuals we know to be under 13. In accordance with the Children’s Online Privacy Protection Act ("COPPA"), if we learn that a child under 13 has provided personally identifiable information, we will either (i) delete this information from our databases, in accordance with our deletion policy, set out in Section 6.3, or (ii) obtain verifiable parental consent, in accordance with COPPA.
11. Relationship to Terms of Use and Other Contracts
This Privacy Policy must be read in conjunction with (i) our Terms and Conditions of Use, and (ii) our Client contracts. To the extent there is a conflict among these documents, (a) the terms and conditions of our Client contract will control both the Privacy Policy and the Terms and Conditions of Use, and (b) the terms and conditions of this Privacy Policy will control the Terms and Conditions of Use.
12. Contact Us
If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Website, please contact us at:
COTO GLOBAL SOLUTIONS
Attention: VICE PRESIDENT MARKETING
Phone: 800 246 2686
Email: information@cotoglobalsolutions.com
13. Effective Data
The effective date of this Privacy Policy is September 22, 2006.
COPYRIGHT AND LEGAL NOTICE.
Copyright ©2006 Tele-Interpreters, Inc. All Rights Reserved.
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