Introduction

The Privacy Policy is designed to: (i) help you understand the types of information Computer Services, Inc. and its subsidiaries and affiliated companies (collectively, “CSI”) may collect from you or that you may provide to us through our Sites (as defined below) and Services (as defined below) and how we collect, use, maintain, disclose, and safeguard that information; and (ii) to assist you in making informed decisions when using our Services.

This Privacy Policy applies when CSI collects and uses your personal data for its own purposes. In some cases, however, you may be accessing or using our Services through a business or organization that is our customer. In those cases, CSI is processing your personal data on that customer’s behalf as a data processor or service provider and in accordance with their instructions. This Privacy Policy does not apply to that processing. Instead, that customer’s own privacy policy governs how your personal data is collected, used, and shared.

For purposes of this Privacy Policy, “Sites” refers to any web properties owned and/or controlled by us including, without limitation, our main corporate website at www.csiweb.com (“Website”), our Facebook, LinkedIn, and X pages, and other social media pages and sites.

“Services” refers to CSI’s products and services accessed through the Sites, from which users can download articles and reports, subscribe to receive newsletters and publications, or contact us to learn more about our products and services and any other solutions or platforms that reference this Privacy Policy.

The terms “we,” “us,” and “our” refer to CSI.

“You” refers to you, as a user of our Sites or Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal data (as defined below) and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Sites or Services. This policy may change from time to time.

This Privacy Policy covers the following topics:

1. Information We Collect About You and How We Collect It
2. Information Collected Through Automatic Data Collection Technologies
3. Universal Opt-Out Mechanism
4. The Data We Collect About You
5. How We Use Your Personal Data
6. Purposes For Which We Will Use Your Personal Data
7. International Transfers
8. Data Retention — How Long Will We Use Your Personal Data?
9. How We Use and Share Your Information
10. How We Protect Your Personal Information
11. Biometric Information We Collect
12. Children’s Privacy
13. Links to Other Websites
14. Your State Privacy Rights and Additional Disclosures
15. Privacy Rights of California Residents
16. Privacy EEA Notice Supplement for the Citizens and Residents of the European Economic Area, United Kingdom and Switzerland
17. Changes to Our Privacy Policy
18. Contact Us

• Related Links

1. Information We Collect About You and How We Collect It

We collect information from and about persons that access or use our Sites or Services. Information may be collected: (i) directly from you when you provide it to us; (ii) automatically when you use the Sites or Services, such information being collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies; or (iii) from third parties. When you access or use our Sites or Services, we may ask you to provide, and we may collect personal data. Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

If you use the chatbot feature on our Sites, you may provide us with any personal data that you choose to provide in your message.

2. Information Collected Through Automatic Data Collection Technologies

As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including: (i) traffic data, location data, logs and other communication data and the resources that you access and use on our Sites; (ii) information about your computer or mobile device and internet connection, including server log data, IP address, operating system information and browser type; and (iii) if you have provided permission through your device to allow us to collect location information, we may obtain your physical location information, from technologies such as GPS, Wi-Fi, or cell tower signals (“Location Information”). You may withdraw your permission for us to acquire your Location Information by changing the permission settings available through your device. We use this information to understand usage patterns on our Sites, such as to determine the parts of our Sites visitors find most valuable. The technologies we use for automatic information collection may include:

• Cookies. A cookie is a small file transferred by a web server and stored on the hard drive of your computer or mobile device. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Sites.
• Web Beacons. Pages of our Sites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
• IP Addresses. An Internet Protocol (“IP”) address is a device’s unique numeric address issued under the registration of the Internet Assigned Numbers Authority, by which it can be located within a network. We may record your IP address when you visit our Sites or use our Services. We may use your IP address to help diagnose problems, to administer the Sites, or to protect our Sites and Services.

When you use our Sites or Services, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: (i) analytics companies that evaluate usage of our Sites and Services; (ii) your mobile device manufacturer; or (iii) your mobile service provider.

These third parties may use Cookies and other tracking technologies to collect information about you when you use our Sites and Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, applications, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

3. Universal Opt-Out Mechanisms

Our main corporate website (www.csiweb.com), Apiture website (www.apiture.com), and Qolo website (www.qolo.io) recognize the Global Privacy Control (“GPC”) signal. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.  

4. The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you which we have identified in our Privacy Policy and grouped together as follows:

5. How We Use Your Personal Data

Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter into or have entered into with you or a contract between you and a third party under which you have given your consent to providing personal data.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation, audit requirement, or applicable law.
• Provide you with our Sites and Services and its content, and any other information that you request from us.
• Provide you with information, products or services that you request from us.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you about changes to our Sites or Services.
• Respond to your comments, questions, and requests, and provide customer service.
• Provide news and information we think will be of interest to you.
• Contact you and respond to any communications that you may have had with us.
• Detect and protect CSI against error, negligence, breach of contract, fraud, theft, and other illegal activity, and to audit compliance with our policies and contractual obligations.
• Record and transcribe calls and meetings for quality and compliance purposes.

6. Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers From Us

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. To the extent allowed by law, you will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing or other information.

Opting Out

You can ask us to stop sending you marketing or other informational messages at any time by contacting us by email at privacy@csiweb.com.

Where you opt out of receiving these marketing and other informational messages, this will not apply to personal data provided to us as a result of a service or work that we performed for you or other similar transactions.

7. International Transfers

We recognize that many countries globally have regulations restricting the flow of personal data across international borders. We have put in place measures to ensure that adequate protection is provided to such data where legally mandated. Whenever we transfer your personal data out of the EEA, the UK or Switzerland, we ensure a similar degree of protection is afforded to it. Please see our Privacy EEA Notice Supplement below for more information.

8. Data Retention — How Long Will We Use Your Personal Data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

9. How We Share Your Information

We may share the information that we collect about you or that you provide to us in the following ways:

Non-Personal Information:

“Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. In general, we use Non-Personal Information to help us improve our Sites and Services and customize the user experience. We also aggregate Non-Personal Information to track trends and analyze use patterns on the Sites. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

Personal Data:

We may share personal data with our contractors, service providers, vendors and other third parties who are performing services for and support CSI, such as the servers for our email communications that are provided access to user’s email address for purposes of sending emails from us. Those vendors use your personal data only at our direction, in accordance with our Privacy Policy and subject to any confidentiality obligations we have undertaken in service contracts to which you or your affiliated institution is a party.

Persons attending CSI’s Annual Customer Conference on behalf of CSI customer financial institutions and other businesses may share their own personal data with other attendees, including exhibitors. CSI does not view such sharing as for CSI marketing purposes nor does CSI receive any consideration for the sharing.

We may share personal data with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.

If we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal data may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your personal data as set forth in this Privacy Policy.

For more information on how we sell personal data with third parties, see our “Your State Privacy Rights and Additional Disclosures” section below.

10. How We Protect Your Personal Data

We have implemented industry-accepted physical and logical security policies and procedures to safeguard against the unauthorized access, disclosure, alteration or destruction of our customers’ information. However, these measures do not guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of such security measures. Any transmission of personal data is at your own risk. By accessing or using our Sites or Services, you acknowledge that you understand and agree to assume these risks.

11. Biometric Information We Collect

Through various technology features, including but not limited to when you upload a photo through one of our Sites and Services, we may collect data from you that potentially falls under the definitions of a “biometric identifier,” “biometric data,” or “biometric information” under applicable state privacy laws.

The above terms are defined by applicable privacy laws and can vary depending on which law applies to you. However, “biometric identifier” is typically defined as a retina or iris scan, fingerprint, voiceprint, scan of hand or face geometry, or other unique biological, physical, or behavioral patterns or characteristics. “Biometric information” typically means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual. “Biometric data” typically means one or more biometric identifiers that are used or intended to be used for identification purposes, whether individually or in combination with other data. For purposes of this section, we will collectively refer to this information as “Biometric Information.”

Any collection of Biometric Information is for the sole purpose of performing identity verification. We will not disclose, redisclose, or otherwise disseminate any Biometric Information to any entity, other than those contracted vendors that assist us in providing this service to you, unless permitted by law. We will not sell, lease, trade, or otherwise profit from your Biometric Information.

We will retain any Biometric Information only until, and shall permanently destroy such data when, the first of the following occurs:

• The date upon which the initial purpose for collecting or obtaining such Biometric Information has been satisfied;
• Twenty-four (24) months after your last interaction with the Company; or
• The earliest reasonably feasible date, and no more than forty-five (45) days after the Company determines that storage of such Biometric Information is no longer necessary, adequate, or relevant to the express processing purpose identified by an annual review conducted by the Company. The Company may extend this forty-five (45) day period by up to an additional forty-five (45) days if reasonably necessary.

Biometric Information will be stored, transmitted, and protected using a reasonable standard of care for our industry, in a manner that is the same as or more protective than the manner in which we store, transmit, and protect from disclosure other confidential and sensitive information. In the event of a data security incident that may compromise the security of Biometric Information, we will promptly investigate the incident and take appropriate measures to mitigate any potential harm. We will notify affected individuals in accordance with applicable law.

Biometric Information will only be collected by us with your prior consent. Before using our identity verification services, you will receive a link to a copy of this Privacy Policy. By clicking “I accept” or a similar phrase you consent to our and our vendors’ collection, use, and storage of your Biometric Information for identity verification purposes.

If you are a Washington resident, our collection of Biometric Information as described above may constitute “consumer health data.” Our collection of such data is necessary to provide the service you are requesting. For more information, please see our Consumer Health Data Privacy Policy.

12. Children’s Privacy

Our Sites and Services are not intended to be used by children, nor do we intentionally collect personal data from children under the age of 18. If you are under the age of 18 years, please do not register or otherwise provide information to CSI on a Site. If we learn we have collected or received personal data 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 our Data Protection Officer at the address below.

13. Links to Other Websites

As part of the Services, we may provide links to other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Sites and Services. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Sites or via our Services. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

14. Your State Privacy Rights and Additional Disclosures

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. For example, California, Colorado, Connecticut, Delaware, Minnesota, New Jersey, Oregon, Texas, and other states have passed privacy laws. If you are a California resident, please see our “Privacy Notice for California Residents.” For other state residents, your privacy rights may include (if applicable):

• The right to confirm whether or not we are processing your personal data and to access such personal data and the categories of personal data we are processing or have processed;
• The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
• The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
• The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
• The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• The right to obtain a list of third parties to which we have disclosed personal data or, depending on the jurisdiction, if we do not maintain this in a format specific to you, a list of third parties to which we have disclosed any consumer’s personal data or categories of third parties;
• If your personal data is profiled in furtherance of decisions that produce legal or similarly significant effects concerning you, you have the right to question the result of the profiling, to be informed of the reason that the profiling resulted in that decision, and, if feasible, to be informed of what actions you might have taken to secure a different decision (and the actions that you might take to secure a different decision in the future). If applicable, you also have the right to review the personal data used in the profiling and, if the decision is determined to have been based upon inaccurate personal data, the right to have the data corrected and the profiling decision reevaluated based upon the corrected data;
• If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
• The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

We use cookies and other tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. When we engage in those activities, we sell personal data (i.e., information from cookies) to third-party advertisers and analytics companies. We do not use personal data subject to applicable state privacy laws for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.

To exercise your rights, please submit a request through our interactive webform available here or by calling us at 1-800-545-4274 extension 3. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting an opt-out request on behalf of another individual, please use the same contact methods described above. We will process authorized agent requests in accordance with applicable law. If we refuse to take action regarding your request, you may appeal our decision through our interactive webform available here or by calling us at 1-800-545-4274. If you would like to opt out of targeted advertising, you may alter your cookie preferences here.

In relation to the personal data we collect and use for our own purposes, we do not collect, use, or sell your personal data for the purpose of training large language models.

Oregon Residents:

CSI is registered as Computer Services, Inc., a Corporation of Kentucky with the Oregon Secretary of State. CSI’s address and telephone number may be found in the Contact Us section.

15. Privacy Rights of California Residents

If you are a resident of the State of California, this Privacy Policy includes by incorporation our Privacy Notice for California Residents, that includes additional information required to be provided under California law and can be found here: https://csiweb.com/privacy-policy/privacy-notice-for-california-residents/. The Privacy Notice for California Residents also includes instructions for California residents wishing to exercise their right to submit a data privacy request under California law.

16. Privacy EEA Notice Supplement for the Citizens and Residents of the European Economic Area, United Kingdom and Switzerland

This European Economic Area (“EEA”) Privacy Notice (“EEA Notice”) supplements the information contained in the Privacy Policy of Computer Services, Inc. (“CSI”). CSI provides this EEA Notice to comply with our obligations as a company that may control and/or process personal data as a part of our business activities related to the EEA, the United Kingdom and Switzerland under the EU General Data Protection Regulation (“GDPR”), UK Data Protection Act, and Swiss Data Protection Act, as applicable. This EEA Notice must be read in conjunction with our Privacy Policy to understand all of the terms that apply to the processing of your personal data. Any capitalized term used in this EEA Notice, but not defined will have the meaning ascribed to it in the applicable privacy act or our Privacy Policy.

CSI EEA Business Activities

Our EEA business activities are primarily in regard to determining whether inquiry subjects are on restricted party screening lists maintained by governmental authorities and other organizations, including among others FBI, Interpol, U.S. Departments of Defense, State and Treasury, the EU, Australia, Canada, England, India, Ireland, Japan, Netherlands, United Nations and the World Bank. Inquiries are most often initiated by companies with which the inquiry subjects wish to engage in business and to which the inquiry subjects have given consents to the inquiries.

Standard Contractual Clauses

With regard to the transfer of personal data from the EU, UK or Switzerland to the United States, CSI relies on the European Commission’s standard contractual clauses (SCCs) that are currently recognized by the EU, UK and Swiss data protection authorities as an alternative data transfer mechanism. We also comply with the Data Privacy Framework as a way to articulate and illustrate our commitment to data subject privacy and provide individuals with an additional legal recourse method that is enforceable in the United States.

Data Privacy Framework – For EU, UK and Swiss Data That is Transferred to the United States

CSI complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. CSI has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. CSI has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

CSI is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC).

The following principles apply to EU, UK and Swiss personal data as described below while it is in the United States:

• Individuals have the right to access their personal data and to update or correct inaccurate information or request deletion of information that has been handled in violation of the principles.
• We may share your personal data with vendors, affiliates or other third parties as described below under “Disclosures of Your Personal Data.” We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party giving rise to the damages.
• We will provide individuals with opt-out choice prior to sending marketing materials.
• Individuals wishing to pursue information rights should contact CSI at the addresses below.
• We may be required to release information in response to lawful requests by public authorities including to meet national security or law enforcement requirements.

In compliance with the EU-US Data Privacy Framework Principles, CSI commits to resolve complaints about your privacy and our collection or use of your personal data transferred to the United States pursuant to the DPF Principles. European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact CSI at: CSI, ATTN: Data Protection Officer, 3901 Technology Drive, Paducah, Kentucky 42001-5201 or email to privacy@csiweb.com.

CSI has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.

Your Legal Rights

• Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Period in which To Respond

We try to respond to all legitimate requests within one (1) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to make a complaint at any time to the proper authority for data protection issues; however, we would appreciate the chance to deal with your concerns before you approach these authorities.

17. Changes to Our Privacy Policy

CSI reviews this Privacy Policy from time to time to ensure compliance with laws, internal procedures and industry standards. We reserve the right to change this Privacy Policy at any time and may not notify you of such changes. We will, however, post the changes on the Privacy Policy page of our Site. The date this Privacy Policy was last revised is identified at the bottom of the page. If we make material changes, we will provide you with additional notice, such as adding a statement on the homepage of our Sites or sending you a notification. You are responsible for periodically visiting our Sites and this privacy page to check for any changes and/or updates to our Privacy Policy.

18. Contact Us

If you have any questions regarding this Privacy Policy or the practices of our Sites, please contact us at:

Computer Services, Inc. (CSI) 
ATTN: Data Protection Officer        
3901 Technology Drive   
Paducah, Kentucky 42001-5201 
privacy@csiweb.com
800.545.4274

Last Reviewed: October 7, 2026