Effective Date: January 1, 2014 Last Updated Date: February 16, 2021
1. About this Privacy Statement
Columbia Forest Products, Inc., together with its affiliates, subsidiaries, successors and assigns (“CFP,” “us,” “our,” and “we”), is committed to protecting the privacy of individuals who visit, use, and actively enter information into the websites located at www.CFPwood.com, www.columbiaforestproducts.com, www.purebondplywood.com and/or www.touchwoodpanels.com (collectively, the “CFP Website”) operated by CFP (collectively, “Users”). Users may at times be referred to in this Privacy Statement as “you.” This Privacy Statement describes CFP’s information practices in relation to your use of the CFP Website. This Privacy Statement also applies to information collected by CFP through offline contacts it may have with you. If you have any questions about this Privacy Statement, please contact CFP at info@CFPwood.com.
PLEASE READ this Privacy Statement carefully before you browse and use the CFP Website. Your usage of the CFP Website signifies to us that you have read and understood all of the terms of this Privacy Statement. You may also be presented with additional opportunities to review this Privacy Statement when taking certain actions on the CFP Website.
This Privacy Statement explains:
- What Personal Information we collect about you when you use the CFP Website, why we collect it, who we disclose it to and how long we keep it for;
- How we use your Personal Information;
- How we protect your Personal Information; and
- Your legal rights in respect to your Personal Information, including how to access and update the information we hold about you.
2. Modifications to this Privacy Statement
We may need to update or revise this Privacy Statement from time-to-time in response to changing legal, technical, or business developments. 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. CFP 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. If we intend to use earlier-collected Personal Information and Automatically-Collected Information in accordance with the terms of the revised Privacy Statement and doing so would result in a use for a different purpose than stated at the time of collection, where required by law we will request your express consent prior to such use. We will keep prior versions of this Privacy Statement in an archive for your review upon request.
3. Personal Information You Voluntarily Provide
When you interact with us through the CFP Website, or offline either directly with CFP or with a manufacturer that we act on behalf of as a distributor or sales agent, you may be asked to voluntarily provide your Personal Information in order to enable us to respond to you, or provide the features you use to interact with us through the CFP Website. As used herein, Personal Information refers to information that identifies, relates to, describes, is associated with, or is reasonably capable of being associated with a particular individual. Some common ways you may be asked to provide Personal Information to us include when you:
- Submit an inquiry form through the CFP Website, or contacting us offline, to learn more about our business, products, or career opportunities;
- Apply for membership in our PureBond® Fabricator Network;
- Make an online or offline request for specific product information or samples, either to CFP or to a manufacturer we act on behalf of as a distributor or sales agent;
- Inquire online or offline about sales of products, such as how to buy products, , either with CFP or with a manufacturer we act on behalf of as a distributor or sales agent;
- Use the CFP Website to subscribe to receive our Newsletter and other information from us.
Depending on the nature of your interaction with us, the Personal Information that we may ask you to provide to us includes the following information:
- your name, home address, email address, telephone number, and other information that could be used to contact you or identify you personally;
- information about your business or profession, including your company or job title, if you have inquired about product sales or applied for membership in our PureBond® Fabricator Network;
- demographic information (such as your postal code to refer you to resources or information in your area);
- employment history and other employment-related information if you’ve inquired about career opportunities; and
- any other information you enter into the CFP Website or provide to us through offline interactions that may be considered Personal Information depending on applicable law, such as a website URL or details about projects you are working on.
See additional information below regarding collection and use of your Personal Information
4. Automatically-Collected Information
CFP uses certain digital analytics tools on the CFP Website that help us analyze site usage and performance when you visit and use the CFP Website. The tools we use include cookies and web beacons, which are discussed in more detail below. The information we collect automatically typically does not include any individuals’ names or contact information. Rather, as you navigate and browse the CFP Website, these analytics tools automatically collect and store 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,” and may be considered Personal Information depending on applicable privacy laws.
This Automatically Collected Information allows us to better understand the visitors to the CFP Website, where they come from, and what content on the CFP Website is of interest to them. It also helps us to maintain the security and operation of the CFP Website. We only ever use this Automatically Collected Information for our internal analytics purposes, to diagnose problems with our servers, and to improve the quality, performance, and functionality of the CFP Website.
5. How We Use Voluntarily Provided Personal Information
As described in section 3, above, you may voluntarily provide Personal Information to us in several ways. PLEASE NOTE THAT YOU DO NOT HAVE TO PROVIDE US WITH YOUR PERSONAL INFORMATION TO BROWSE THE CFP WEBSITE, AND 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 to interact with us. When you do provide us your Personal Information, you are authorizing us to use that information to fulfill the purposes identified herein in accordance with the terms of this Privacy Statement and to store your information on our servers located in the United States. You understand that your Personal Information may be subject to the laws of the United States, and that it may be accessible to governments, tribunals, law enforcement and regulatory agencies in the United States.
a. Use of Personal Information to Perform Services Requested and to Contact You
CFP uses Personal Information provided by Users to perform the services they request. For example, if you request product information or samples, CFP will use the information provided to contact you about your interest in our products, or to send you the requested product samples. 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
CFP may also use Personal Information provided by Users for marketing purposes. For example, if you inquire about CFP products, CFP may use your Personal Information that you provide to contact you to further discuss your interest in CFP products and to send you information regarding CFP, which may include 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 info@CFPwood.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), depending on the nature of our business relationship with you, we may still contact you for non-marketing purposes relating to your use of the CFP Website or otherwise in regard to our business relationship with you.
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.
d. Employment and Recruiting
As described above, if you are interested in employment or career opportunities with CFP we will ask you to provide certain Personal Information required for the application and recruiting process. If you provide information online in order to apply for a job with CFP, please note that you will be using and providing information through www.ultipro.com, which is a third party service provider we use to assist us with receiving online job applications. This service provider is required to keep your Personal Information confidential. CFP 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. CFP does not sell this Personal Information, and does not allow third parties to use this Personal Information for their direct marketing purposes. Further, 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. If you have set up a portfolio for job applications through www.ultipro.com, you may access, update or change your Personal Information associated with your portfolio at any time by accessing and/or editing your portfolio.
6. Collection and Use of Automatically-Collected Information
As described above, CFP uses commonly-used information-gathering tools, such as cookies and web beacons, to collect Automatically-Collected Information as you navigate the CFP Website. CFP also uses Automatically-Collected Information to operate and improve the CFP Website, including track what Users are looking at most frequently so we can recognize and deliver more of the desired features, products, and services. This section describes in further detail the types of Automatically-Collected Information CFP may collect and how CFP may use this Automatically-Collected Information.
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 CFP when browsing the CFP Website; in other words, the cookie alone does not enable 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.
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. Information about managing cookies in commonly used browsers is available online from www.allaboutcookies.org. 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.
b. Web Beacons
CFP 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 CFP. 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, CFP may place web beacons in marketing emails that notify CFP when you click on a link in the email that directs you to the CFP Website. CFP 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.
c. IP Addresses and Mobile Device IDs
When you visit the CFP Website, our digital analytics tools collect your Internet Protocol (“IP”) addresses and/or mobile device IDs to track and aggregate Automatically-Collected Information. For example, CFP uses IP addresses and mobile device IDs to monitor the regions from which Users navigate the CFP Website in order to help us to maintain the security and operation of the CFP Website.
7. Third Party Cookies and Website Analytics;
a. Third Party Analytics
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. In order to gather this Automatically-Collected Information, we use a Google Analytics cookie on the CFP Website. When you visit the CFP Website, Google Analytics automatically collects information from you through the use of Google’s analytics IDs, and Google provides some of this information to us. An analytics ID is a specific string of numbers and letters (often called a “character string”) that is assigned to your computer or device but does not name you. The analytics ID allows Google to track usage data of the CFP Website, such as date and time of visit, duration of visit, Website traffic patterns, “clickstreams,” other similar information about your use of the CFP Website, the type of web browser used, the operating system/platform you are using, your IP address, the websites that referred or linked you to the CFP Website, and your CPU speed. Google Analytics does not share the analytics ID assigned to your computer or device that you use to access and use the CFP Website. Google Analytics provides information about the use of the CFP Website to us in aggregate form (i.e., data about many CFP Website users combined and not just about you). Some of this data might include the regional location of CFP Website users, but again, this data will be in aggregate (and not individual) form. We rely on this aggregate data to inform us how users are using the CFP Website and to help us improve the CFP Website.
b. Social Media Widgets
Some pages of the CFP Website include social media features, such as “buttons” or “widgets that we place on our Websites. If you use these features they may collect your IP address, which page you are visiting on the CFP Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third-party or hosted directly on the CFP Website. See the Social Media Features section under the heading How We Share the Personal Information We Collect, below, for more details about your interactions with these features on our Websites.
8. How We Share the Personal Information We Collect
CFP may share your Personal Information in the manners described in this section. In addition, CFP may also share aggregated Automatically-Collected Information that has been de-identified or otherwise rendered anonymous without restriction.
a. Sales Agents
CFP does not sell its products directly to consumers, but rather utilizes a network of select wholesale distributors and retailers (collectively, “Sales Agents”) to sell CFP products. CFP may share contact information voluntarily provided by Users who are interested in purchasing CFP’s products with its designated Sales Agents so that these Sales Agents can respond directly to User inquiries about CFP product sales on CFP’s behalf. CFP does not sell User data to its Sales Agents, and Sales Agents are not permitted to use User Personal Information provided by CFP for any purpose other than as described in this Privacy Statement. As noted above, CFP acts as a distributor on behalf of some manufacturers. At times CFP may receive contact information provided to the manufacturer by Users who are interested in purchasing the manufacturer’s products. However, CFP does not disclose Personal Information to any third party manufacturers unless, and limited to the minimum amount necessary, disclosure is required in order to fulfill a purchase or order (for example, shipping information).
b. Third-Party Service Providers
CFP may provide your Personal Information and Automatically Collected Information to third party service providers to perform certain services for us, including: to perform certain marketing on our behalf, such as through our newsletter or promotional e-mail campaigns; to manage our employment and recruiting process; to perform website analytics services, as described above in this Privacy Statement; and to provide other services relating to the operation of the CFP Website (such as hosting, data storage, and security). CFP does not sell User Personal Information to any third parties. Rather, any disclosure of Personal Information to third party service providers is solely to enable the service provider to perform the requested services on CFP’s behalf. These third-party service providers are not authorized to use your information received from CFP in any way, including for their own marketing efforts, other than for the purpose of providing a service on our behalf, and are required to keep the information confidential.
c. Job Applications
As described in the Employment and Recruiting section, above, information you provide online in order to apply for a job with CFP will be processed through www.ultipro.com, which is the service provider CFP uses to assist us with managing employment and recruiting processes. This service provider is required to keep your Personal Information confidential. CFP does not sell your information to this service provider, nor do we allow the service provider to use your information for its own marketing purposes, or for any other purpose than providing the services on our behalf.
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 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, CFP 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.
g. Social Media Features
These features might require us to implement cookies, plug-ins, or application programming interfaces (APIs) provided by such social media platforms to facilitate the communications and features. When you provide us with information through these platforms, the information also becomes subject to their privacy statements. In addition, by choosing to use any third party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. We cannot control any policies or terms of such third party platform. As a result, we cannot be responsible for any use of your information or content by a third party platform, which you disclose at your own risk. We encourage you to review the privacy statements of these platforms.
9. Accessing, Correcting and Updating Your Information; Your Rights Regarding Your Information
a. Access, Review and Modification of Information; Deleting Information
If you have set up a portfolio for job applications through www.ultipro.com, you may access, update or change your Personal Information associated with your portfolio by accessing and/or editing your portfolio, as described in the Employment and Recruiting section, above. For all other purposes, CFP Website Users may access, update or change their Personal Information by sending us an email request to info@CFPwood.com. If you want us to delete your Personal Information from our databases, please contact us at info@CFPwood.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.
b. Your Rights Regarding Your Personal Information
If you are based in certain jurisdictions, you may have certain rights in relation to the Personal Information we hold about you. These may include the right to request to:
- access details related to the Personal Information CFP has collected about you, for example the categories of Personal Information collected, the sources of those categories, the business or commercial purposes for collecting Personal Information, any third parties with whom Personal Information is shared, and the specific pieces of Personal Information collected about you;
- rectify any incorrect or incomplete Personal Information we hold about you
- delete, restrict, or remove the Personal Information we hold about you
- transfer the Personal Information we hold about you to another party; or
- object to the sale of your Personal Information (please note that CFP does not currently sell Personal Information, nor has it sold any Personal Information in the preceding 12 months).
We will attempt to respond to your requests within one month and free of charge. Please note that with regard to all these rights, we reserve the right to:
- verify proof of your ID to process the request, or request further information for this purpose;
- refuse your request based on the exemptions set out in any applicable data protection laws;
- charge you a reasonable administrative fee for any repetitive, manifestly unfounded, or excessive requests.
If we refuse your valid request to exercise any of these rights which you may have, we will state the reasons for our refusal and allow you to challenge our decision. If we have shared your Personal Information with others, we will inform them about your request where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly. If you wish to exercise any data protection rights that are available to you under your local data protection laws then please send your request to info@CFPwood.com or call our corporate office at 1-800-637-1609 and we will act upon your request in accordance with applicable data protection laws.
Your California Privacy Rights
Please note, as described throughout this Privacy Statement, CFP does not disclose Personal Information to third parties for their direct marketing purposes.
Notwithstanding the above, if you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your Personal Information with third-parties. Specifically, California law provides you the right to submit a request to us at the designated address in the “Contact Us” section below to receive the following information:
- the categories of information we disclosed to third-parties for the third-parties’ direct marketing purposes during the preceding calendar year;
- the names and addresses of third-parties that received such information; and
- if the nature of a third-parties’ business cannot be reasonably determined from the third-parties’ name, examples of the products or services marketed.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually.
10. Children’s Privacy
The CFP Website is not directed at nor intended for use by children under the age of 13. Further, CFP will never use or disclose any Personal Information of a child under either the age of 18, or the age of majority in jurisdictions where such age is greater than 18, for marketing or advertising purposes. If you are under age 18, or under the age of majority in jurisdictions where such age is greater than 18, you should not provide CFP with Personal Information about yourself if you use the CFP Website. If we learn that we have received Personal Information or Automatically-Collected Information from a child under either the age of 18, or the age of majority in jurisdictions where such age is greater than 18, we will delete that information from our files.
11. Security of Collected Information
CFP uses commercially-reasonable physical, electronic, and administrative security measures to assist in protecting against the loss, misuse, and unauthorized alteration of Personal Information that is under our control. This includes, depending on the nature and sensitivity of the information or system, the use of firewalls, encryption of data, voluntary vulnerability scans and penetration testing, workforce training and education, and other security measures. 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 or when you interact with us.
12. Do Not Track
The CFP Website does not track your online activities over time and across third-party web sites or online services, and so does not respond to browser “Do Not Track” signals. As described in this Privacy Statement, the CFP Website may contain links to other websites not owned or operated by CFP. These websites may set cookies that obtain information about the fact that a web browser visited the CFP Website from a certain IP address. These websites are not authorized to collect any other personal data from the CFP Website unless you provide it to them directly.
13. Retention, Storage and Removal
We may retain all Personal Information and Automatically-Collected Information in our databases for long as necessary to perform the business purposes for which we’ve collected it, or until you ask us to remove your information from our databases, unless applicable laws require otherwise. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or aggregate it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 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.
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.
14. Links to Other Websites
This Privacy Statement applies only to Personal Information and Automatically-Collected Information collected through the CFP Website or that you otherwise provide to CFP. 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, including our information practices related to our use of or disclosures to Sales Agents and service providers, should be directed to info@CFPwood.com or by contacting us using the information below:
By Phone to our Corporate Office: 1-800-637-1609
By mail to:
Columbia Forest Products
7900 McCloud Road
Greensboro, NC 27409