Last Modified Date: August 2023
CoreTrust Purchasing Group LLC (“CoreTrust,” “we,” “us,” or “our”) provides our website https://www.coretrustpg.wpenginepowered.com/ (“Website”) and the services available therein, including the CoreTrust Experience Platform (“Platform”) and the group purchasing services (“GPO Services”), to you (“you” or “your”), and hosts tradeshows, conferences, or conventions (“Events”) (collectively, “Services”) where your information may be collected. This privacy policy (“Privacy Policy”) explains our privacy practices when you use the Services and the types of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as defined by applicable privacy laws (“Personal Information”) that we may collect or receive from the Services or any other web address, application, or mobile site controlled by CoreTrust that links to this Privacy Policy.
By accessing and using the Services, or otherwise providing information to CoreTrust, you consent to the terms of this Privacy Policy, and consent to our privacy practices described herein including our use and disclosure of your Personal Information. If you do not agree to the terms and conditions of this Privacy Policy, including having your Personal Information used in any of the ways described in this Privacy Policy, do not provide us with your information. Please note, however, that if you do not provide us with your information, you may not be able to use or participate in certain features of the Services.
We reserve the right to revise or update this Privacy Policy at any time, and you should periodically read the Privacy Policy to learn of any revisions or updates. We will notify you of any changes to the Privacy Policy by posting the revised or updated Privacy Policy and its “Last Modified” date on this Website. If the revision or modification is material, we will provide you notification via email or via the Services. Your continued use of the Services after the “Last Modified” date constitutes your acceptance of and agreement to the Privacy Policy and its revisions or updates.
The Services may permit you the opportunity to provide us with Personal Information. We may collect certain information, including Personal Information, from and about you in various ways, including:
a. Information Collected Directly from You or From Your Authorized Agent on Your Behalf
Either from filling out an online contact form or providing information at Events, we may collect the following Personal Information directly from you or from your authorized agent, such as your employer, portfolio company, or private equity firm, on your behalf:
b. Information Collected Directly from You When You Use the Platform
We may collect the following Personal Information directly from you when you use the Platform:
c. Information Automatically Collected When You Use Our Website
We may automatically collect data about you when you use our Website. This information is primarily used to maintain the security and operation of our Website, and for our internal analytics in connection with our GPO services. This information may include:
We use information collected from cookies and other technologies to improve your user experience and the overall quality of our Website and connected GPO services. We use cookies to help us identify and track visitors, your usage of our Website, and your access preferences. We may use your Personal Information to see which web pages you visit our Website, which websites you visited before coming to our Website, and where you go after you leave our Website. We can then develop statistics that help us understand how our visitors use our Website and how to improve it. If you do not wish to have cookies placed on your computer, you should set your browsers to refuse cookies before using our Website. Please understand that if you do so, you may not be able to fully utilize our Website and therefore we disclaim, and you hereby waive, any claim or liability that may arise due to your partial or incomplete access to the content of any of our website as a result thereof.
Third Party Cookies
CoreTrust may process your Personal Information for the following lawful business and commercial purposes, in accordance with the practices described in this Privacy Policy:
Except as otherwise described in this Privacy Policy, we do not sell, share, rent, or otherwise disclose your Personal Information that we collect from the Services to any third parties for monetary or other valuable consideration, unless stated below or with your consent:
We may share and disclose de-identified and/or aggregate analytics with third-party partners for the purposes described in this Privacy Policy or where it is collected, or any other legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with Personal Information.
You have choices about how we use your information. Please understand that if you choose not to disclose information to us, it may affect your ability to use some features of our Services or connected GPO services.
a. Marketing. If you have supplied your email address in relation to our Services, we may further send you emails or notifications via the membership portal to provide you with information, to inform you of new events or content, to solicit your feedback, or to keep you up to date on us. You can opt out of our marketing and promotional communications at any time by clicking Unsubscribe or otherwise following the opt out prompts on these communications. You also may ask us not to send you other marketing communications by contacting us as specified in the “Contact Us” section below, and we will honor your request. Please note that even after you are removed from our marketing lists, we may still send you non promotional communications, such as responding to service requests.
b. Advertisements. Advertisements appearing on any of our Website may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by us and does not cover the use of cookies by any advertisers.
We and our service providers may use information about your interactions with our Website to predict your interests and select the ads you see on and off our Website. This is known as interestbased advertising. In providing interest-based ads, we follow the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance (“DAA”). For more information about interest-based advertising and how you can opt out, visit:
Digital Advertising Alliance: http://www.aboutads.info/choices/
Network Advertising Initiative: http://www.networkadvertising.org/choices/
c. Do Not Track Disclosure. Many web browsers include a Do-Not-Track (“DNT”) feature or setting that signals your preference not to have data about your online browsing activities monitored and collected. However, there is currently no uniform standard for recognizing and implementing the DNT signals. As such, we do not monitor or respond to Do Not Track browser requests. If a standard is adopted that we must follow in the future, then we will inform you about that practice in a revised version of this Privacy Policy.
Our Website may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us—and which may link to other websites, services, or applications. Please be aware that we are not responsible for the privacy or practices of other websites or third parties. We do not make any guarantee regarding those third-party websites, services, or applications, and we are not liable for any loss or damage caused by the use of such sites. Any data collected by third parties is not covered by this Privacy Policy. You should review the policies of the third parties and contact them directly if you have any questions about their services or practices.
CoreTrust values your privacy and is committed to protecting your information. We have appropriate administrative, technical, and physical safeguards in place to ensure the integrity and security of your information. We undertake commercially reasonable efforts to guard against unauthorized access, use, alteration, or destruction of Personal Information.
We keep your personal data only as long as necessary to provide you with our services and for legitimate and essential business purposes, such as maintaining the performance of our Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal information for as long as you are a registered member of our services.
We do not knowingly collect or solicit personal information from children under the age of 18. By providing information via the Services, you represent that you are at least 18 years old. If you are under 18, please do not provide information via our Services. If we become aware that we have inadvertently received or collected Personal Information from a child who is under the age of 18, we will attempt to immediately delete that information from our files and records. If you believe a child who is under the age of 18 has provided us with Personal Information, please contact us at the address listed below in “Contact Us.”
We occasionally offer contests via our Website or in-person at Events. To participate in these contests, we may require you to provide us with Personal Information, such as your name, company, title, email address, and phone number. We will use the information you provide us for purposes including administering the contest and other purposes disclosed in contest rules and policy. We do not sell any Personal Information provided to us. If you have any questions or concerns, please contact us via the Contact Us section below.
This section explains how we collect, use, and disclose Personal Information about users, customers, and visitors who reside in California (“consumers” or “you”). It also explains certain rights afforded to consumers under California’s Shine the Light law and the California Consumer Privacy Act of 2018 (“CCPA”), as revised and updated by the California Privacy Rights Act (“CPRA”). This section uses certain terms that have the meaning given to them in the CCPA including Personal Information.
a. Shine the Light
Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the Contact Us section below with a reference to California Disclosure Information.
b. Categories, Purpose, & Sources of Personal Information Collected
We may collect (and have collected during the 12-month period prior to the “Last Modified” date of this Privacy Policy) the categories of Personal Information from the sources and for the purposes as described in the above sections Collection of Personal Information, Purpose of Collection, and Collection of Personal Information.
c. Selling and Sharing Personal Information
We do not sell or share your Personal Information in exchange for monetary consideration; however, we may use tools described above such as Google Analytics, which may be interpreted as sharing your Personal Information. As such, please see the above Personal Data Automatically Collected and Choices sections for more information regarding opting out of use of these tools.
During the 12-month period prior to the “Last Modified” date of this Privacy Policy, we may have shared or disclosed the following categories of Personal Information about you for a business or commercial purpose with certain categories of third parties, as described below:
Categories of Personal Information that May Be Sold, Shared, or Disclosed | Categories of Third Parties to whom Personal Information May Be Sold, Shared, or Disclosed | Business or Commercial Purpose of Selling, Sharing, or Disclosing Personal Information |
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Platform Information |
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Internet or Other Electronic Network Activity |
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d. California Consumer Privacy Rights
Under CCPA, consumers have certain rights regarding their Personal Information, as described below.
If you would like to exercise your California privacy rights, please refer to the Consumer Requests and Verification section below.
a. Right to Non-Discrimination
We may not discriminate against you because you exercise any of your privacy rights contained in this Privacy Policy including, but not limited to:
b. Verifying Requests
You may request to exercise your rights of access, deletion, or correction by contacting us as described in the Contact Us section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request. If you request access to or deletion of your Personal Data, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address. When you make such a request, you can expect the following:
c. Authorized Agents
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the Contact Us section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:
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