Privacy Policy
C3 Pathways, Inc. (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://www.c3pathways.com or use our mobile applications, progressive web applications, and software products, including any other media form, media channel, mobile website, mobile application, web application, or software related or connected thereto, whether now existing or released in the future (collectively, the “Site”). The Site includes our software products and related online services described in the section “C3 Software and the C3 Cloud” below. Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.
COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The information we may collect on the Site includes:
Personally identifiable information, such as your name, email address, telephone number, mailing address, organization, job title, and role, that you voluntarily give us when you register for an account, a course, or an event, purchase products or services, request information, subscribe to communications, or otherwise contact us. If you make a purchase, payment information may be collected and processed by our third-party payment processors.
Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. If you are using our mobile applications, this information may also include your device name and type, your operating system, your phone number, your country, your likes and replies to a post, and other interactions with the application and other users via server log files, as well as any other information you choose to provide.
We publish mobile applications in the Apple App Store and Google Play, such as our Active Shooter Incident Management Checklist app, and progressive web applications (“PWAs”) that run in a web browser and may be installed on a device, such as the NCIER Instructor app, the NCIER Knowledgebase app, the C3 Pathways MCADI app, and internal applications used by our personnel. We release new and updated applications from time to time, and this Privacy Policy applies to each of them, whether or not it is named here. Depending on the application and the permissions you grant, if you connect using one of our mobile applications or PWAs we may collect:
- Account Information. Your name, email address, organization, role, sign-in credentials, and sign-in records.
- Device Information. Your device type and model, operating system and version, unique device and advertising identifiers, browser type, application version, language, time zone, and mobile network information.
- Geolocation Information. Location-based information from your device, including precise location, when you allow location access. You may change this in your device settings.
- Push Notifications. Device tokens and notification preferences, if you allow notifications. You may turn notifications off in your device or browser settings.
- Device Access and Content. Photos, files, camera, microphone, contacts, calendar, or other device features and content, when you grant the application permission to access them.
- Local and Offline Storage. Information stored on your device, such as cached content, settings, and data saved for offline use through service workers, local storage, or similar technologies. This information may remain on your device until you clear it or uninstall the application.
- Usage and Diagnostic Data. How you use the application, features used, content viewed, performance data, error and crash reports, and log files.
- Content You Provide. Checklists, forms, notes, expense records, receipts, images, messages, and other information you enter or upload.
The specific information an application collects depends on its features and on the permissions you grant. Many permissions can be changed in your device or browser settings, but some application features may not work without them.
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site, our mobile applications, or our software to:
- Provide, operate, maintain, secure, and support the Site, our applications, and our software.
- Create and manage accounts, process registrations, orders, and payments, and deliver products and services.
- Send administrative, account, and support communications.
- Send newsletters, promotions, and other marketing communications, and deliver targeted advertising and remarketing.
- Measure and analyze the effectiveness of our marketing, websites, and campaigns.
- Develop and improve our products and services.
- Resolve disputes and troubleshoot problems.
- Monitor and analyze usage and trends to improve your experience with the Site and our mobile applications.
- Increase the efficiency and operation of the Site and our mobile applications.
- Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
- Comply with legal obligations and enforce our agreements.
- Create aggregated or de-identified information, which we may use for any lawful purpose.
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
We may share your information with third parties that perform services for us or on our behalf, including hosting, data storage, payment processing, email delivery, marketing automation, analytics, customer service, and map services.
We may share your information, including information collected through cookies and similar technologies, with advertising and analytics partners, such as Google and Meta (Facebook), to deliver, measure, and improve advertising and remarketing.
We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.
If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honor commitments we made in this Privacy Policy.
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.
C3 SOFTWARE AND THE C3 CLOUD
This section applies to our software products, including Counterstrike Terrain, NIMSPro (including our virtual reality software), and any other software, application, or online service we provide now or in the future, together with the hosted services that support them (the “C3 Cloud”). Use of our software is also governed by the C3 Software License Agreement or other written agreement under which it is licensed. All information described in this section is part of the information we collect through the Site, and it may be used and disclosed as described anywhere in this Privacy Policy.
- Account Data, such as names, email addresses, organization, role, and sign-in credentials for the users of our software.
- Customer Content, meaning the data, documents, maps, plans, images, and other content that users create, upload, or store using our software.
- Web Session Data. Some of our software includes a built-in web browser. Cookies, sign-in sessions, and similar data created in that browser are stored on the device and may be synchronized to the C3 Cloud with the user’s account.
- Usage Data and Telemetry. Our software, including Counterstrike Terrain, automatically sends us usage, performance, diagnostic, and crash information, license and activation check-ins, and device and software version information.
Our software may store information locally on your device, including an offline copy of Customer Content, and may synchronize that information with the C3 Cloud. Information stored locally is the responsibility of the device owner. The C3 Cloud is hosted by third-party providers, which may change from time to time. Our software may also use third-party map services, such as Mapbox, which receive map requests and related device information when you use mapping features.
We generally retain information for as long as an account remains open and afterward for as long as we consider it useful for business purposes or as required by law. Inactive accounts may remain dormant without automatic deletion. We are not obligated to retain any information, including Customer Content, and we may delete it at any time without notice. We are not required to delete information except as required by law. We are not responsible for the loss, corruption, or unavailability of any information, including as a result of security incidents or hardware, software, or service provider failures.
Information that government agencies store using our software may be subject to public records laws, including Chapter 119, Florida Statutes. The agency, not C3 Pathways, is the custodian of its public records and is responsible for responding to public records requests.
Our software is not designed to store classified information, Controlled Unclassified Information, Criminal Justice Information, protected health information, or payment card data, and you must not store such information in it.
TRACKING TECHNOLOGIES
We may also partner with selected third-party vendors, such as Google Analytics, to allow tracking technologies and remarketing services on the Site and our mobile applications through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site and our mobile applications, determine the popularity of certain content and better understand online activity. By accessing the Site or our mobile applications, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. If you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.
The technologies we use include, without limitation:
- Google Analytics 4 and Google Tag Manager, to measure and analyze use of the Site and our applications.
- Advertising and remarketing services, such as Google Ads and the Meta (Facebook) pixel and software development kit, which may show you our advertisements on other websites and platforms based on your visits to the Site.
- Marketing automation, such as Mautic, which may track your visits to the Site, your interactions with our emails, and your form submissions, and associate that activity with your contact information once you identify yourself to us.
- Campaign tracking parameters (UTM codes), tracking pixels, and web beacons in links, advertisements, and emails, to identify how you reached the Site and to measure the effectiveness of our campaigns.
We may add, change, or stop using any of these vendors or technologies at any time without updating this list.
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
THIRD-PARTY WEBSITES
The Site and our mobile applications may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site or our mobile applications, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site or our mobile applications.
GOOGLE MAPS
This website and certain of our applications use Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.
By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service.
Our software products may use other map services, such as Mapbox, as described in the section “C3 Software and the C3 Cloud.”
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and our mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
The Site, our mobile applications, and our software are intended only for users who are at least 18 years of age. If you are under 18 years of age, reside in California, and have nonetheless publicly posted content on the Site or our mobile applications, you may request removal of that content. To request removal, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the content is not publicly displayed on the Site or our mobile applications, but please be aware that the content may not be completely or comprehensively removed from our systems.
C3 Pathways does not currently meet the thresholds that define a “business” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and those laws therefore do not apply to us. If that changes, we will update this Privacy Policy.
CONTACT US
If you have questions or comments about this Privacy Policy, please contact us at:
Phone: 407-490-1300
Fax: 877-347-4137
Toll Free: 877-340-4032
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