Effective Date: January 1, 2020
Columbia Forest Products, Inc., together with its affiliates, subsidiaries, successors and assigns (“Company,” “us,” “our,” and “we”), is committed to protecting the privacy of individuals who visit, use, and actively enter information into the Columbiaforestproducts.com and/or Columbiaforestproductsblog.com websites (collectively, the “CFP Website”) operated by Company (collectively, “Users”). Users may at times be referred to in this Privacy Statement as “you.” This Privacy Statement describes the Company’s information practices in relation to your use of the CFP Website. This Privacy Statement also applies to information collected by the Company through offline contacts it may have with you. If you have any questions about this Privacy Statement, please contact the Company at firstname.lastname@example.org.
IMPORTANT NOTICE: Please see the information in the Section entitled “Sharing of Information Collected” for an understanding regarding the parties with whom we may share your information, how they will use your information (including for direct marketing purposes), and how you may opt-out of our sharing of your information with these third parties.
1. Your Agreement to this Privacy Statement
Please read this Privacy Statement carefully before you browse and use the CFP Website. Your usage of the CFP Website signifies that you have read, understand, and agree with all of the terms of this Privacy Statement. You may also be required to click-to-agree to this Privacy Statement when taking certain actions on the CFP Website. If you are acting on behalf of an entity, you represent that you have full authority to bind your entity to this Privacy Statement. If you do not have such authority or if you do not agree to all of the terms of this Privacy Statement, do not use the CFP Website. You agree that this Privacy Statement is supported by reasonable and valuable consideration, the receipt and sufficiency of which are hereby acknowledged. Without limiting the generality of the foregoing, you acknowledge that such consideration includes your use of the CFP Website.
2. Modifications to this Privacy Statement
We reserve the right to update and revise this Privacy Statement at any time. We will post any new or revised Privacy Statement here, and you should review this Privacy Statement regularly to make sure that you are aware of its terms. You can determine if this Privacy Statement has been revised since your last visit to the CFP Website by referring to the effective date or last updated date at the top of this Privacy Statement. The Company will also provide notification of significant changes to this Privacy Statement through the CFP Website. In addition, if changes are significant, we may notify you of such changes via the Personal Information (defined below) that you have provided to us, if any. Your use of the CFP Website following such updates or revisions to this Privacy Statement constitutes your acceptance of and agreement to the terms of this Privacy Statement, as updated or revised by us, and the revisions will apply to the Personal Information and Automatically-Collected Information (defined below) collected on and after the date on which we post the updated or revised Privacy Statement. If we intend to use earlier-collected Personal Information and Automatically-Collected Information in accordance with the terms of the revised Privacy Statement, we will request your express consent to do so. We will keep prior versions of this Privacy Statement in an archive for your review upon request.
3. Personal Information Collected
Personally-identifiable information that we may collect includes information such as your name, home or business address, email address, telephone number, fax number, and other information that could be used to contact you or identify you personally; demographic information (such as your zip code); your username and password; details regarding your entity and its products (including without limitation number of employees, annual revenue, and years in business); employment history and other employment-related information; and any other information you enter into the CFP Website or provide to us through offline contacts, such as email or phone call (hereafter, “Personal Information”). See additional information below regarding collection and use of your Personal Information.
4. Automatically-Collected Information
As you navigate and browse the CFP Website, the Company automatically collects and stores information about your visit to and use of the CFP Website, such as: The date and time of your visit, the duration of your visit, the type of browser and browser language you use, your Internet Protocol (“IP”) address, mobile device ID, type of computer or other operating device used, the actions you take on the CFP Website (such as the web pages viewed and the links clicked), the websites (if any) from which you linked to the CFP Website, and the website(s) you visit after visiting the CFP Website. All such information is referred to in this Privacy Statement as “Automatically-Collected Information.” We collect Automatically-Collected Information through the use of commonly-used information-gathering tools, such as cookies and web beacons, which are discussed in more detail below. Unless otherwise stated in this Privacy Statement, Automatically-Collected Information may be combined with your Personal Information. See information below regarding our use of Automatically-Collected Information to track your online activity and deliver targeted advertising.
5. Collection and Use of Personal Information
Personal Information may be provided by you to us in several ways, including without limitation, when you contact us through the CFP Website, when you express an interest in obtaining additional information about the products we offer, when you apply for membership in our PureBond® Fabricator Network, and when you apply for jobs. In order to engage in any of the foregoing activities, you must provide us your Personal Information.
YOU DO NOT HAVE TO PROVIDE US WITH YOUR PERSONAL INFORMATION TO BROWSE THE CFP WEBSITE, AND WE ONLY COLLECT PERSONAL INFORMATION FROM YOU WHEN YOU VOLUNTARILY PROVIDE IT TO US. YOU ARE NEVER UNDER ANY OBLIGATION TO PROVIDE YOUR PERSONAL INFORMATION. However, if you do not provide your Personal Information, you may not be able to use certain features of the CFP Website. When you do provide us your Personal Information, you are authorizing us to use that information in accordance with the terms of this Privacy Statement and to store your information on our servers located in the United States.
a. Use of Personal Information to Perform Services Requested and to Contact You
The Company uses Personal Information of Users to perform the services requested. For example, if you request product information, the Company will use the information provided to contact you about your interest in our products. If you apply for membership in the PureBond® Fabricator Network, we will use that information to consider your application and, if you become a member, the information will be associated with your membership. Or if you apply for a job, we will use the information provided to consider you for the position and to contact you regarding your application. We may also use your Personal Information to contact you regarding your use of the CFP Website and/or to provide required notices.
b. Use of Personal Information for Marketing Purposes
The Company may also use Personal Information of Users for marketing purposes. For example, the Company may use Personal Information you provide to contact you to further discuss your interest in CFP products and to send you information regarding the Company and its partners, such as information about promotions or events. At any time, you may request that we stop contacting you for marketing purposes by sending an email with your request to email@example.com. Also, if we use your Personal Information to send you marketing communications via email, we will provide you with an unsubscribe mechanism to opt-out of receiving future marketing communications. If you request that we not contact you for marketing purposes (either by using the unsubscribe mechanism or by sending us an email), we reserve the right to contact you for non-marketing purposes relating to your use of the CFP Website. Please see important information below regarding third parties with whom we share your Personal Information for their direct marketing purposes.
c. Use of Personal Information and Automatically-Collected Information Generally
We also may use both Personal Information and Automatically-Collected Information to help diagnose problems with the CFP Website, to analyze statistical use patterns and demographic data, and to improve our products and services. We may use your Personal Information and Automatically-Collected Information to customize and tailor your experience using the CFP Website, displaying content we think you might be interested in and according to your preferences.
6. Collection and Use of Automatically-Collected Information
The Company uses commonly-used information-gathering tools, such as cookies and web beacons, to collect Automatically-Collected Information as you navigate the CFP Website. This section describes in further detail the types of Automatically-Collected Information the Company may collect and how the Company may use this Automatically-Collected Information.
The Company may use Automatically-Collected Information to operate and improve the CFP Website. We may also use Automatically-Collected Information to track what Users are looking at most frequently so we can recognize and deliver more of the desired features, products, and services.
The CFP Website uses a feature of your Internet browser called “cookies” to make your interactions with the CFP Website easy and meaningful. When you visit the CFP Website, our servers send a cookie to your computer or other operating device. The cookie is placed on your hard drive or other operating device, and it assigns your computer or operating device a unique, random number that acts as a sort of anonymous ID. Standing alone, cookies do not personally identify you; rather, a cookie identifies the computer or operating device used to access the CFP Website. A cookie cannot read data off of your hard drive. Unless you choose to identify yourself to us, such as by responding to a promotional offer or filling out a web form, you remain anonymous to the Company when browsing the CFP Website; in other words, the cookie alone with not allow us to identify you personally. There are two types of cookies: Session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer or operating device when you close your browser software or otherwise end your session. Persistent cookies remain on your computer or operating device after you close your browser or otherwise end your session. We use session cookies to provide us information about CFP Website features used and activities conducted while using the CFP Website. We also use third-party persistent cookies to help us deliver advertising based on your online activity, as described in Section 7 below.
Most browsers automatically accept cookies, but you can disable the acceptance of cookies at any time by changing the preferences in your browser. Most browsers also allow you to change the settings to require that the browser notify you when you receive a new cookie. Please refer to your browser for information on how to disable and control cookies. If you disable your web browser’s ability to accept cookies, you will be able to browse the CFP Website, but you may not be able to successfully use certain features of the CFP Website. Further, note that in order to stop receiving our advertisements based on your online activity, you will need to opt-out of this online tracking, as described in Section 7.
b. Web Beacons
The Company uses web beacons alone or in conjunction with cookies to compile Automatically-Collected Information about your usage of the CFP Website, as well as your interaction with emails from the Company. Web beacons are clear electronic images imbedded in a web page, website feature, or email, which can recognize certain types of information on your computer or other operating device, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon. For example, the Company may place web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to the CFP Website. The Company uses web beacons to operate and improve the CFP Website and email communications and to statistically monitor how many people are using the CFP Website and opening our emails and for what purposes. We do not collect Personal Information with web beacons.
c. IP Addresses and Mobile Device IDs
When you visit the CFP Website, the Company collects your Internet Protocol (“IP”) addresses and mobile device IDs to track and aggregate Automatically-Collected Information. For example, the Company uses IP addresses and mobile device IDs to monitor the regions from which Users navigate the CFP Website.
7. Third Party Cookies and Website Analytics; Our Targeted Advertising Practices
We use third-party services, including SkyGlue and Google Analytics, to track and analyze your CFP Website activity, as well as to track websites you visit after using the CFP Website. We do not combine this Automatically-Collected Information with your Personal Information. In order to gather this Automatically-Collected Information, we use a Google Analytics cookie on the CFP website.
We may also use other third-party services, such as Google AdWords and Google Display Network, to serve online advertisements to you on other websites after you’ve visited the CFP Website. This practice is known as remarketing, and you will see our advertisements across the Internet unless you opt-out, as discussed below. We, along with third-party vendors, SkyGlue, Google, and DoubleClick, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and deliver advertisements based on your online activity, including your past visits to the CFP website. If you would like to learn more about this program, you can do so here.
If you would like to opt-out of receiving targeted advertising like this from Google, you can manage these settings by visiting the Google Ads settings page. Also, Google recommends installing the Google Analytics Opt-out Browser Ad-on. Alternatively, you can opt-out by visiting the Network Advertising Initiative opt-out page (https://tools.google.com/dlpage/gaoptout). Note that even if you opt-out, you may still see CFP advertisements, but they will not be delivered based on your online activity.
The advertisements described in this Section are different from marketing communications you will receive if you are on our promotional mailing list, which is discussed in Section 5(b) above.
8. Sharing of Information Collected
The Company may share your Personal Information in the ways described below. Also, note that this Privacy Statement is provided on behalf of Columbia Forest Products, Inc., together with its affiliates and subsidiaries, all of whom may have access to your Personal Information for use in accordance with this Privacy Statement. The Company may also share de-identified, aggregated Automatically-Collected Information without restriction.
a. Sales Agents; Third-Party Service Providers
The Company may share Personal Information about Users with the Company’s sales agents and other third-party service providers so that these agents and service providers can contact Users who have provided contact information on our behalf to perform certain services for us, perform certain marketing on our behalf, and/or perform website analytics services, as described above, or other services relating to the operation of the CFP Website (such as hosting, data storage, and security). The Company may also share Personal Information of our Users with the Company’s agents and service providers to ensure the quality of information provided. These third-party service providers are not authorized to use your information in any way other than as described here and are required to keep the information confidential.
b. Third Parties for Their Direct Marketing Purposes
UNLESS PROHIBITED BY LAW, WE MAY SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES (INCLUDING WITHOUT LIMITATION CABINETMAKER MAGAZINE) SO THAT THEY MAY SEND YOU MARKETING COMMUNICATIONS PROMOTING THEIR PRODUCTS AND SERVICES. Even if you discontinue use of the CFP Website and no longer have a relationship with the Company, we may continue to share your Personal Information as described in this notice. However, at any time (whether you have a continuing relationship with the Company or not), you can contact us to limit our sharing of your Personal Information with third parties for their direct marketing purposes. You may contact us to request that we not share your Personal Information with unrelated third parties for their direct marketing purposes. You may also contact us to request that we not share your Personal Information with our affiliates and subsidiaries for their direct marketing purposes. See the Section below entitled “Correcting and Updating Your Information; Opt-Out Rights” for instructions regarding how to contact us to request that we stop sharing your Personal Information with unrelated third parties and/or our affiliates and subsidiaries for their direct marketing purposes.
c. Job Applications
If you provide information online in order to apply for jobs at Columbia Forest Products, please note that you will be using and providing information through www.ultipro.com, which is a vendor we use to assist us with receiving online job applications. The Company will be given all of the Personal Information you provide as part of your online portfolio and as part of job applications you submit, and we will only use this Personal Information to consider your application(s) and as part of your personnel file if you are hired. For example, we will not provide this Personal Information to third parties for their direct marketing purposes. We do not allow the operator of the www.ultipro.com website to use your Personal Information submitted as part of your portfolio or to apply for jobs for any purpose other than to process job applications, and this vendor is required to keep your Personal Information confidential.
d. Merger, Acquisition, or Sale
We may transfer any and all Personal Information and Automatically-Collected Information to a third party if CFP is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings in which information of Users is among the assets transferred. In this event, we will, if allowed, use reasonable efforts to notify you when your Personal Information and Automatically-Collected Information is transferred to any third party under this paragraph by posting such notice on the CFP Website and/or by contacting you via the Personal Information you have provided us, if any. Unless you consent otherwise, we will require the third party to agree to only use your Personal Information in accordance with the promises made in this Privacy Statement, even after the transfer. But any new information you provide after the transfer will likely be subject to a new policy, and you should review that policy.
e. Required by Law
Notwithstanding anything to the contrary in this Privacy Statement, the Company reserves the right to disclose your Personal Information and Automatically-Collected Information, without your consent and without additional notice to you, if we reasonably believe we are required by law, rule, regulation, judicial proceeding, court order, subpoena, or similar legal process to do so; if we reasonably believe that disclosure is necessary to protect, establish, or exercise our rights or property, or to defend against legal claims; or if we reasonably believe that disclosure is necessary to protect our other Users or our employees, property, or business, or to take action regarding illegal activities or suspected fraud.
f. Public Areas of the CFP Website
The CFP Website contains areas where Users can post content that will be viewed by other Users, such as our blog. You should be aware that when you voluntarily disclose Personal Information on these areas for public viewing, the information may be collected, stored, used, and disclosed by other Users. Such activities are beyond our control, and we shall have no responsibility for or liability regarding the protection or security of such information. Do not post Personal Information that you want to keep private on these areas of the CFP Website.
9. Correcting and Updating Your Information; Opt-Out Rights
a. Stop Marketing Communications
See the Subsection entitled “Use of Personal Information for Marketing Purposes” above regarding how to unsubscribe from future marketing communications from us. Also, you may contact us at any time via the contact information shown here to be removed from the list of our Users whose Personal Information we share with third parties (including unrelated third parties and/or our affiliates and subsidiaries) for their direct marketing purposes.
Columbia Forest Products
General Information and Sales
7900 McCloud Road
Greensboro, NC 27409
b. Stop Targeted Online Advertisements
See Section 7 above regarding how to opt-out of receiving targeted CFP advertisements based on your online activity.
c. Review and Modification of Information; Deleting Information
If you have set up a portfolio for job applications through www.ultipro.com, you may update or change your Personal Information associated with your portfolio by editing your portfolio. For all other purposes, CFP Website Users may update or change their Personal Information by sending us an email request to firstname.lastname@example.org. If you want us to delete your Personal Information from our databases, please contact us at email@example.com. Upon receipt of your request to delete or to change your Personal Information, we will use commercially-reasonable efforts to remove your existing Personal Information from our databases, but see the Section entitled “Retention and Storage” below regarding why we may retain some information. Please note that all features of the CFP Website may not function properly if we remove any or all of your Personal Information.
10. Intended Users of the CFP Website
The CFP Website is intended for adults only. By accessing, browsing, or using the CFP Website, you affirm (i) that you are eighteen (18) years old or older, or that you are between the ages of thirteen (13) and seventeen (17) and possess legal parental consent or guardian consent to use the CFP Website and provide information through the CFP Website; (ii) that you are a United States resident; and (iii) that you have authority to agree to this Privacy Statement and are competent and capable of understanding and complying with this Privacy Statement. The CFP Website is not directed at children under the age of thirteen (13), and children under age thirteen (13) are prohibited from using the CFP Website. The Company does not and will not knowingly permit submission of Personal Information by anyone under thirteen (13) years of age through the CFP Website. The Company does not and will not knowingly contact children under the age of thirteen (13) for marketing purposes. If we learn that we have received Personal Information or Automatically-Collected Information from a child under age thirteen (13), we will delete that information from our files.
11. Security; Disclaimer
The Company uses commercially-reasonable physical, electronic, and managerial security measures to assist in protecting against the loss, misuse, and unauthorized alteration of Personal Information that is under our control. When the CFP Website is accessed using Internet Explorer version 8.0 or later, Firefox version 2.0 or later, or Safari version 5.0 or later, Secure Socket Layer (“SSL”) technology protects your Personal Information using both server authentication and data encryption during transmission. The Company hosts the CFP Website in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. The Company also offers enhanced security features that permit Users to configure security settings to their level of comfort.
Here are additional details regarding the security measures we take:
a. Physical Security
Our production equipment is collocated at a facility that provides 24-hour physical security, redundant electrical generators, and other backup equipment designed to keep servers continually up and running.
b. Data Encryption
The Company leverages encryption products to protect User data and communications, including 256-bit irreversible SSL Certification. The lock icon in the browser indicates that data is shielded from access while in transit.
c. Operating System Security
The Company provides operating system-level security by using a minimal number of access points to all production servers. We protect all operating system accounts with strong passwords, and production servers do not share a master password database. All operating systems are maintained at each vendor’s recommended patch levels for security and are hardened by disabling and/or removing any unnecessary users, protocols, and processes.
d. Database Security
Whenever possible, database access is controlled at the operating system and database connection level for additional security. Access to production databases is limited to a number of points, and production databases do not share a master password database.
e. Server Management Security
Company employees do not have direct access to the Company’s server production equipment, except where necessary for system management, maintenance, monitoring, and backups. The Company’s engineering team provides all system management, maintenance, monitoring, and backups.
The safety and security of your Personal Information also depends on you. Users who have created profiles via the www.ultipro.com website are responsible for keeping usernames and passwords confidential. Also, you should not send us sensitive Personal Information via email, as this is not secure. Please notify us if you become aware that your Personal Information is lost, stolen, or used without permission.
Unfortunately, no data storage system, or system of transmitting data over the Internet or wireless network, can be guaranteed to be 100% secure, and no security system can prevent all security breaches. As a result, we do not and cannot guarantee the security of our servers or any Personal Information or Automatically-Collected Information provided to us in connection with your use of the CFP Website. Any transmission of your Personal Information and Automatically-Collected Information to us through the CFP Website or through www.ultipro.com is at your own risk.
12. Security Researchers: CFP Website Vulnerability Reporting Policy
Security researchers seeking information on how to report security issues to the Company should review and comply with the following:
The Company acknowledges the valuable role that independent security researchers play in Internet security. Keeping our Users’ data secure is important to us, and we encourage responsible reporting of any vulnerabilities that may be found in the CFP Website. The Company is committed to working with the security community to verify and respond to any potential vulnerabilities that are reported to us. Additionally, the Company pledges not to initiate legal action against security researchers for penetrating or attempting to penetrate our systems as long as they adhere to the following conditions:
a. Testing for Security Vulnerabilities
Conduct all vulnerability testing against demonstration websites of our online services to minimize the risk to our Users’ data. Contact and request domain names for demonstration websites at firstname.lastname@example.org.
b. Reporting a Potential Security Issue
Privately share details of the suspected vulnerability with the Company by sending an email to email@example.com. Provide full details of the suspected vulnerability so the Company may validate and reproduce the issue.
c. The Company does not permit the following types of research:
- Causing, or attempting to cause, a Denial of Service (DoS) condition.
- Accessing, or attempting to access, data or information that does not belong to you.
- Destroying or corrupting, or attempting to destroy or corrupt, data or information that does not belong to you.
d. The Company’s Commitment to Security Researchers:
To all security researchers who follow this Vulnerability Reporting Policy, Company commits to the following:
- To respond in a timely manner, acknowledging receipt of your report
- To provide an estimated time frame for addressing the vulnerability
- To notify the reporting individual when the vulnerability has been fixed
e. No Compensation
The Company does not compensate people for reporting security vulnerabilities, and any requests for such compensation will be considered a violation of the conditions above.
13. Retention and Storage
We may retain all Personal Information and Automatically-Collected Information in our databases until you ask us to remove your information from our databases, unless applicable laws require otherwise. Note that even after you ask us to remove your information from our databases, it may be impossible to remove some information, such as information tracked in our web server log files and information that may reside in backup files. This residual information is retained to preserve the integrity of our backed-up files and for business continuity purposes. We may also retain Automatically-Collected Information even after you request that we remove your information from our databases, for use in the aggregate and to analyze and improve the CFP Website. Your Automatically-Collected Information may be retained for the purpose of serving targeted online advertising to you until you opt-out of receiving these advertisements, as described in Section 7 above. Further, even after you request that we remove your information from our databases, we may retain Personal Information and Automatically-Collected Information to comply with any applicable law, rule, regulation, or guideline; to prevent fraudulent activity; to protect ourselves against liability; and to allow us to enforce our contractual or other rights and to pursue available remedies and limit any damages we may sustain.
This Privacy Statement applies only to Personal Information and Automatically-Collected Information collected through the CFP Website. The CFP Website may contain links to other websites that are not owned or controlled by us (“Linked Sites”). We are not responsible or liable for and have not reviewed the privacy practices of the Linked Sites, or the owners or operators of the Linked Sites. The owners and operators of the Linked Sites may have their own policies regarding privacy and security. We advise you to review any Linked Sites for their own privacy practices to determine what information about you may be collected and used when you use such Linked Sites.
If any part of this Privacy Statement is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision, and the remainder of the Privacy Statement shall continue in full force and effect.
16. Contacting Us
Questions regarding this Privacy Statement or the information practices pertaining to the CFP Website should be directed to firstname.lastname@example.org or
Columbia Forest Products
General Information and Sales
7900 McCloud Road
Greensboro, NC 27409