Depending on the nature of our relationship with you, in the past twelve months we may have collected the following types of personal information about you:
Types of Data and Collection Methods
Passively Tracked Data:
As a result of your use of this Website, Cabot may, itself or through a third-party vendor, passively collect technical and usage Data from you, the User, pertaining to your computer and/or Internet connection. Such Data may include internet or other network activity (e.g., the number and frequency of your visits to this Website, information regarding websites accessed immediately before and after your visit to this Website, your Internet browser type, and your preferences on our Website), and identifiers (e.g., your IP address). The technical and usage Data may be used to assist Cabot’s web design team in maintaining and improving this Website, and to enhance and/or personalize your visits to this Website.
Actively Tracked Data:
Cabot may also collect and store Data, or engage a third party vendor to collect and store Data, voluntarily provided by you while visiting this Website. User provided Data may include identifiers such as contact information or professional or employment-related information (e.g., information provided while seeking employment at Cabot, including but not limited to your resume or other personal information).
Collection Purposes, Use of Data
Cabot collects your personal Data for the purpose of establishing and managing our business relationship with you or your organization, understanding the market in which Cabot operates, management reporting, website management, and managing security, risk and crime prevention.
Cabot processes your Data on one or more of the following legal grounds, where appropriate:
- Your consent;
- Processing is necessary for the performance of a contract to which you are a party;
- Processing is necessary for compliance with a legal obligation; or
- Processing is necessary for the purposes of the legitimate interests pursued by Cabot.
Disclosures of Personal Information
Cabot will not sell or rent your personal and/or proprietary Data to anyone. We also share your Data with agents and service providers who use the Data, under confidentiality agreements, for our purposes only and only under our instructions, e.g., third parties who provide us on-site web analytics services (for example, website tracking, content delivery, etc.). Depending on the nature of our relationship with you, we may disclose Data as described above to any of these third parties for our business purposes. We may share your Data as required by law or in the interest of protecting or exercising our or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. Also, we reserve the right to fully use and disclose any Data collected via the Website that is not in personally identifiable form.
We may share your information with the following types of service providers:
- Technical support providers who assist with our website and IT infrastructure;
- Third party software providers, including “software as a service” solution providers, where the provider hosts the relevant personal data on our behalf;
- Subcontractors or suppliers that need your information for processing orders;
- Professional advisers such as lawyers, accountants, tax advisors, auditors and insurance brokers;
- Our advertising and promotional agencies and consultants and those organizations selected by us to carry out marketing campaigns on our behalf; or
- Providers that help us store, collate and organize information effectively and securely, both electronically and in hard copy format, and for marketing purposes.
Your General Rights
To the extent provided by the law of your jurisdiction or as otherwise applicable to our processing of your information, you may have certain rights regarding your data. These rights may include: the right to access the personal information that we hold about you, including the purpose for processing the Data, the categories of recipients of that data, and the source of that information. You may also have the right to request deletion of your personal information, subject to certain limitations.
Rights for UK and EU Residents
Cabot is committed to the protection of personal Data in line with the data protection principles set out in the European General Data Protection Regulation (“GDPR”). This section describes the steps Cabot takes to protect the personal Data that it processes about customers, business partners, and residents that reside in the UK or EU.
Where Cabot uses your email to communicate marketing information to you, we will seek your prior consent where required to do so by law.
If and when transferring your Data outside the EU, we will do so using one of the following safeguards:
- Transfer to a non-EU country which has an adequacy decision by the EU Commission;
- Cover the transfer with a contractual agreement which covers the GDPR requirements relating to transfers to countries outside the EU;
- Transfer to an organization which has Binding Corporate Rules approved by an EU data protection authority; or
- Transfer to an organization in the US that is EU-US Privacy Shield certified.
International transfers within Cabot’s group are governed by EU Commission-approved Standard Contractual Clauses for Controllers (as defined by the GDPR) and, where relevant, for Processors (as defined by the GDPR).
The GDPR provides you with certain rights in relation to the processing of your personal data, including:
- To request access to your personal Data which enables you to receive a copy of the personal Data we hold about you, and to check that we are lawfully processing it.
- To request rectification, correction, or updating to any of the personal Data that we hold about you which enables you to have any incomplete or inaccurate information Cabot holds about corrected.
- To request personal Data provided by you to be transferred in machine-readable format to the extent applicable in the business relationship context.
- To request erasure of personal Data which enables you to ask Cabot to delete or remove personal Data where there is no good reason for Cabot’s continuing to process it. You also have the right to ask us to delete or remove personal Data where you have exercised your right to object to processing.
- To request the restriction of processing your personal Data which enable you to ask Cabot to suspend the processing of your personal Data.
- To object to the processing of your personal Data in certain circumstances, where the processing of your personal Data is based on legitimate business interests or where decisions about you are based solely on automated processing.
- To withdraw your consent in those circumstances where Cabot may rely on your consent to process your personal data.
These rights are not absolute and are subject to various conditions under the laws and regulations to which Cabot is subject.
You also have the right to lodge a complaint with the competent data protection Supervisory Authority, if you are not happy with how Cabot processes your personal Data and we could not provide you with a satisfactory resolution to your request.
Rights for California Residents
The California Privacy Protection Agency, as enforced by relevant privacy laws (namely, Title 1.81.5 California Consumer Privacy Act of 2018), requires Cabot to make certain additional disclosures and provides California residents with certain rights regarding their personal information. If you are a California resident, this section describes those rights, how you may exercise them, and what Cabot will do in response.
If you are an individual who resides in California and whose personal information is collected and processed by Cabot, your rights are:
- To request that Cabot disclose, free of charge, the categories and specifics your personal Data, the sources from which your personal Data was collected, and the business purpose for collecting your personal Data.
- To correct or justify any inaccurate personal Data.
- To limit use and disclosure of sensitive personal Data.
- To opt-out of the sale of personal Data (Cabot does not sell personal information currently).
- To non-discriminatory treatment should you choose to exercise any of the rights listed here.
- To initiate a private cause of action for any data breaches involving your sensitive Data.
- To request that Cabot deletes the personal Data it has collected unless a legal exception applies.
Cabot will keep and process your personal Data only for as long as is necessary for the purposes for which it was collected in connection with your relationship with use, unless we have a legal right or obligation to retain the Data for a longer period, or the data is necessary for the establishment, exercise, or defense of legal claims.
Transmissions over the Internet are never 100% secure or error-free. However, with respect to our internal security procedures, Cabot takes reasonable steps to maintain physical, electronic, and procedural safeguards in order to protect your personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Cabot also requires third party companies that we hire and to whom we disclose Data to keep such information confidential and to use it only to perform the services for which we hire them and only under our instructions.