Culpepper Privacy Policy Culpepper Compensation Surveys and Services
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Culpepper Privacy Policy
Your Privacy is Important to Us

We respect your privacy and are committed to protecting it through our compliance with the following policy about how the information and data you share with us is collected, used, and secured.

We collect a limited amount of personal information so that we can inform you about our products and services and improve your experience and use of our website and online tools. We do not sell, exchange, or disclose your personal information to third parties.

We take our obligations seriously to secure the data we collect, as well as your right to understand how we use and control your personal data.

This includes the implementation of internal processes and controls to ensure compliance with applicable data protection and privacy laws globally, including the European Union General Data Protection Regulation ("EU GDPR") and the California Consumer Privacy Act (“CCPA”).

Culpepper Privacy Policy

This policy describes the types of information Culpepper and Associates, Inc. ("Company" or "We") may collect from you or that you may provide when you visit the website culpepper.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy is adopted to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this policy.

This policy applies to information we collect:
  • On this website, including using automated technologies and forms or surveys that you voluntarily complete.
  • In email, text, and other electronic messages between you and this website.
Consent to Use or Processing of Your Information
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our website. By accessing or using this website, you agree to this privacy policy and consent to our use of your information for the purposes set forth in this privacy policy. You may also be asked from time to time to consent to certain specified uses of your information. When you are asked to consent, you have the right to withdraw that consent at any time by changing settings in your account or notifying us at privacy@culpepper.com.

This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this website after we make changes is deemed to be acceptance of those changes and consent to our continued use of your information for the purposes set forth in the revised privacy policy. Please check the policy periodically for updates.

Information We Collect About You and How We Collect It
We collect information that identifies, relates to, describes, references, or could reasonably be associated with or linked, directly or indirectly with a particular consumer, household, or device ("personal information"). Personal information does not include:
  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
  • Personal identifiers. Examples include a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples include a name, signature, address, telephone number, education, employment, employment history, credit card number, or debit card number.
  • Commercial information. Examples include records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other similar network activity. Examples include information on a user's interaction with our website, advertisements, referral source, communication preferences, and content requested or downloaded from our website, as well as information about internet connection, the equipment used to access our website and usage details.
  • Geolocation data. Approximate physical location as determined by a user's IP address.
  • Professional or employment-related information. Examples include current employment status, employer, and job title.
We collect this information:
  • Directly from you when you provide it to us, such as when you create an account or complete a form or survey.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
  • From third parties, for example, our business partners (which may include your employer).
Information You Provide to Us
The information we collect on or through our website may include:
  • Information that you provide by filling in forms on our website. This includes information provided at the time of registering to use our website, subscribing to our service, newsletter, or other communications, or requesting information about us or our services. We may also ask you for information when you report a problem with our website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that you complete.
  • Details of transactions you carry out through our website and fulfillment of orders. You may be required to provide financial information before placing an order through our website.
  • Compensation information provided by you or your employer ("Survey Data") for use in connection with our compensation survey platform, website, data, reports, materials, online tools, and related survey data services ("Culpepper Survey Data"). However, Culpepper Survey Data does not constitute personal information and is therefore not subject to this policy.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our website, we may use automatic data collection technologies to save certain information about your device, browsing actions, and patterns, including:
  • Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website.
  • Information about your device and internet connection, including your IP address, operating system, and browser.
We do not track to collect information about your online activities over time and across third-party websites and therefore do no respond to Do Not Track signals.

The information we collect automatically may include personal information. It helps us to understand your service and product needs, how you use our website, to improve our website and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, recognize you when you return to our website, store information about your preferences, allowing us to customize our website according to your individual interests, provide you with enhanced and directed compensation data services and products, and send you service, marking, and sales information about our Company.

The technologies we use for automatic data collection include:
Cookies. A cookie (a.k.a., browser cookie, internet cookie, web cookie) is a small text file saved on your device when you visit a website. Cookies enable sites to help identify visitors and enrich user experience with saved preferences and customized content.

We use cookies to make it possible for us to save your website preferences, recognize you when you return, and save information you provide in online forms and surveys. This enables us to provide you a more customized experience based on your individual needs, interests, and interactions on our website. We also use cookies to understand how you use our site, which guides our decisions to improve our website content, functionality, and related services.

We use the following types of cookies on our websites:
  • Session cookies are used to maintain relevant information about your individual visits and transactions on our website. Typically, session cookies expire when you close your browser or turn off your device.
  • Persistent cookies are used to recognize you when you return to our website, save basic user information and preferences, save information provided on forms and surveys, and provide customized content and functionality.
  • Google Analytics cookies are used to collect information about how visitors find and use our website.
  • Qualtrics Survey cookies are used for surveys hosted by our partner Qualtrics. These cookies maintain and keep track of survey sessions so that they are not repeated.
Option to Block Culpepper Cookies. You have the option to block cookies used by our websites by adjusting the settings in your browser. However, please note that if you choose to block cookies used by our websites, you may not be able to access or use pages and services that require the use of cookies.

Consent to Use Culpepper Cookies. If you continue to use our websites without changing your cookies settings, you give your permission to our use of cookies.

For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.

Clear Gifs. Pages of our website may contain small electronic files known as clear gifs (also referred to as web beacons, pixel tags, and single-pixel gifs), which are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. These allow us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity and effectiveness of certain website content and verifying system and server integrity).
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
  • To present our website and its contents to you.
  • To provide you with information about surveys, products, research, and services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your participation in our surveys, including participation solicitations, reminders, and survey results.
  • To allow you to participate in interactive features on our website.
  • To provide you and your organization with customized content and features of our online surveys and software tools.
  • To publish Culpepper Survey Data.
  • To provide you with notices about your account, survey subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our website or any products or services we offer or provide through it.
  • For any other purpose with your consent. If you are asked to consent to the use of your information, you have the right to withdraw that consent at any time by notifying us at privacy@culpepper.com.
We may also use your information to contact you about surveys, products, research, and services that may be of interest. If you do not want us to use your information, please notify us at privacy@culpepper.com. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information - Not for Sale
Unless otherwise noted in this privacy policy or at the time of collection, all personal information collected is for our exclusive use and is not sold, rented, shared, or otherwise provided to third parties.

Culpepper Survey Data is only published in anonymized, aggregate form. We hold individual company and employee-level survey data in strict confidence. Security and data sufficiency controls are in place to ensure that we do not disclose your company's compensation practices or personally identifiable information (PII) of your employees.

Customized report outputs and online tools that display your company's data, you-to-market comparisons, and data for individual employees are restricted to licensed users authorized by your company.

We do not sell, exchange, or disclose company-identifiable or employee-identifiable survey data to third parties.

Nor do we do sell, exchange, or disclose your personal information to third parties. However, we may disclose personal information that we collect, or you provide, as described in this privacy policy:
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide information.
  • With your consent.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users is among the assets transferred.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply agreements with us, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
  • Cookies. You can configure your browser to block all or some of the cookies used on our website or to alert you when cookies are being used. If you block cookies on our website, please note that some parts of this website may be inaccessible or not function properly.
  • Promotional Offers and Survey Solicitations from Culpepper. If you do not wish to have your contact information used by Culpepper to promote our products and services or solicit your participation in our surveys, you can opt-out or customize your preferences by sending an email to privacy@culpepper.com.
  • Interest-Based Advertising. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used. You can opt-out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
  • Retention of Information. We retain the personal information you provide for as long as your account exists or as required to provide you the website and any surveys, products, or services. We retain survey data as needed to provide Culpepper Surveys and other products or services.
Your Rights and Choices.
The CCPA provides consumers located in California with specific rights regarding their personal information. We extend these rights to all consumers located in the United States. This section describes your rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

You should be aware that if your personal information is deleted, your user account will also be deleted. Also, deleting or altering the processing of your personal information will impact your user experience on the website. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:
  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at privacy@culpepper.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to the personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Additional Rights
You can review and change your personal information by logging into the website and visiting your account profile page. You may also contact us to request access to, correct or supplement any personal information that you have provided to us, and to request confirmation of whether we process your personal information. While we do not disclose information to third parties for marketing purposes, California residents may request certain information regarding such disclosures in accordance with California Civil Code Section § 1798.83.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may, from time to time, offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Information Security
The security of your personal information is important to us. We have implemented reasonable administrative, physical, and technical security safeguards to secure your personal information from unauthorized access, use, alteration, destruction, and disclosure.

We protect your personal information by using standard practices, procedures, and security technologies, including limited access, IT controls, encryption, and the use of secure data center facilities.
  • Only a limited number of authorized and trained employees have access to your personal information.
  • Our service providers, contractors, and business partners are bound by contractual obligations to keep personal information confidential and only use it for authorized purposes.
  • All personal information sent to us via our website is encrypted both in transit, via secure HTTPS connections, and at rest on servers behind firewalls in secure data centers located in the United States.
Despite safeguards, the security of information transmitted via the internet cannot always be guaranteed. You acknowledge this by accessing and using our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the site. If you have reason to believe that your interactivity with us is no longer secure or that your Culpepper account has been compromised, please notify us immediately at privacy@culpepper.com.

Users Located Outside of the United States
Culpepper and Associates, Inc. is located and headquartered in the United States (U.S.). Our website is hosted in the U.S., and our services and products are provided in and from the U.S. If you are visiting or providing information from a country outside of the U.S., the laws governing data protection, collection, or use where you are located may differ from U.S. laws.

Although this policy is designed to provide a consistent level of protection for personal information all over the world (including compliance with the EU GDPR, as applicable), you are transferring your data (including personal information) to the U.S., which may have different data protection laws than the country where you are located. By providing us your data (including personal information) through your use of our website, you consent to:
  • the use of your personal information as described in this policy;
  • the transfer of your personal information to and the access, use, storage, and other processing of your personal information in, the U.S.; and
  • exclusive jurisdiction for the resolution of any issues related to your data (including personal information) issues in the state or federal courts located in Fulton County, Georgia, United States of America.
Website for Business Use - Not Intended for Children
Our website is designed for business use by executives, HR professionals, finance professionals, and other management. It is not intended for consumers or children under 18 years of age. No one under age 18 may provide any information to the website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this website or on or through any of its features. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@culpepper.com.

Links to Third-Party Websites
Our website may contain links to other third-party websites, which are outside of our control and not covered by this policy. Culpepper is not responsible for the privacy practices or content of those sites. If you have questions about the privacy practices of non-Culpepper websites, you should contact those sites directly.

Changes to Our Privacy Policy
This policy may change from time to time. Your continued use of this website after we make changes is deemed to be acceptance of those changes and consent to our continued use of your information for the purposes set forth in the revised privacy policy. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account or through a notice on our website. The date the privacy policy was last revised is identified near the bottom of this page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this privacy policy to check for any changes.

Contact Information
To ask questions or comment about this privacy policy and our privacy practices, or if you would like to exercise any of your rights or make a company about a breach of this policy, contact us at:
Culpepper and Associates, Inc.
3780 Mansell Road, Suite T-40
Alpharetta, GA 30022 United States
privacy@culpepper.com
+ 1 770-641-5400
You also have the right to contact your local government or supervisory authority.

This Privacy Policy was last updated on August 19, 2020.