PRIVACY POLICY
KCoe Isom, LLP (collectively, “us”, “we,” and “KCoe”) values our customers, their information, privacy and trust. This Policy explains how we collect, use, handle, and protect information collected through our website. Specifically, this Policy applies to KCoe’s collection, use, storage, and transfer of information associated with KCoe’s site, www.kcoe.com (collectively, “Site”). If there is something you do not understand about our privacy practices, please feel free to contact us at kcoe@kcoe.com.
Throughout this Policy, we refer to the term “Personal Information.” “Personal Information” is data about an individual who can be identified from that data, or by combining it with other data. Personal Information is usually your name in combination with another identifier, such as date of birth, postal address, email address, telephone number, or government-issued identification number. The specific definition of Personal Information varies from one jurisdiction to another.
Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data.
We do not consider Business Information, such as one’s position, business name, title, business email, business phone number, business address, business fax, and other similar business information, to be Personal Information.
Information We Collect
Information Collected Directly From You
We collect personal information from you in connection with your payment for services through our Site in our legitimate interest in processing payments for services and marketing our business. Specifically, we collect personal information such as your name, billing and shipping address, phone number, and email address. This information is collected so that we can process your payment, including updating you on the status of your account and delivering the products or services you ordered. We also use the email addresses you provide to send information about products or services that may be of interest to you. For information we collect from you to complete a purchase, we retain that information as long as necessary to complete the order. We will keep your name, address, and other location information until the payment is processed or the service is completed and for up to sixty (60) days after to ensure you receive your product and/or service. We may keep your contact information for an additional year from the last time you contact us in order to send you marketing materials on new and related services to those you may have purchased or show interest in, but you can opt out of those materials by following the instructions found in those communications.
Our partners on this Site, Quickfee, Authorize.net, and International Bank Card, may collect additional information during the processing of payment transaction on our behalf (including your credit card number, billing address, telephone number, and credit card information number, type of card, expiration date, and CVV number) also as part of our legitimate interest in processing payment for our services. Your credit card information is only kept for as long as necessary to process the payment and then is deleted from their system. We recommend that you review the Terms and Conditions, Privacy Policies, and other policies and agreements found on our partners’ pages to fully understand what information of yours is being collected and how it is being used.
We will collect your name, your email address, the subject of your inquiry, and information about any questions or concerns you raise with us. We use this information to respond to your request, improve the operation of our Site, conduct research and analysis of how our customers use our Site and assess which of our products and services may be of interest to you. When you contact us via the company email address, we will collect your email address and any information you include in your email to similarly address your concerns.
When you apply for a job through our Site, you will be asked to provide your name, email, address, and information about your employment history, skills, and abilities. That information is provided to or partner iCims who collects and maintains that information for us. If you have questions about how iCims handles your data, please refer to their Privacy Policy.
We collect your email address and your password when you create an account on our Site and use that information to confirm your identity when you log in to your account. We also collect your email address if you indicate on our Site that you would like to receive additional information about us and use that email address to send you that information. We will keep your account information (including your name, login, and account preferences) for as long as you have an account with us to allow us to verify your identity and to provide you with the account information you request. In addition, we may retain personal information from closed accounts to comply with national laws, professional obligations, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use and take other actions permitted or required by applicable laws.
Our Site is not directed to children under age 13 and we do not knowingly collect Personal Information from children under the age of 13. Children under 13 should not provide their Personal Information to us through our Site, to member service, or in writing. If we learn that Personal Information belonging to anyone under the age of 13 is stored on the Site, we will immediately delete such information and refrain from using it for any purpose.
Other Information We Collect
In addition to collecting information directly from you as described in the previous section, we also automatically gather information when you browse or view our Site. This information may include Internet Protocol (IP) address, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, clickstream data, and whether you are a first-time or a returning user, links you clicked on while on the Site, and your flow and navigation path through the Site during your visit. We use this information to make sure that the Site, and its associated parts, is functioning properly, that the Site is displayed properly for your equipment and software, and that we can provide you with information useful to you.
There are “do not track” or similar browser choices available to internet users with respect to online web activity, but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our Site will not operate any differently when a “do not track” signal is received.
In some of our email messages, you may find a “click-through URL” linked to content on our Site. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our member communications. If you prefer not to be tracked in this way, you should not click such links in our email messages.
Cookies
We use technologies such as “cookies” so we can remember certain information about you, remember your preferences or recognize you when you return. They also help us compile aggregate data about Site traffic and Site interaction so that we can improve our Site and protect our Site from fraud.
A cookie is a text file that stored on your computer. As text files, cookies cannot read information on your hard drive, run programs or deliver viruses to your computer.
Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered. If you decline cookies, you may find that you cannot access all of our Site’s features.
During your browsing session, we use “session” cookies to store information and monitor Site function. These session cookies are installed during your browsing session and are deleted when the browsing session has ended. We use the following session cookies when you visit our Site:
| Cookie | When Deleted | Purpose |
| apbct_cookies_test
apbct_page_hits apbct_timestamp apbct_visible_fields_count apbct_site_landing_ts apbct_prev_referer apbct_visible_fields |
When the browsing session ends | Used for Spam protection, AntiSpam, Firewall |
| ct_pointer_data
ct_checkjs ct_fkp_timestamp ct_ps_timestamp ct_timezone |
When the browsing session ends | Used to prevent incoming spam |
| woocommerce_cart_hash
woocommerce_items_in_cart |
When the browsing session ends | Used to monitor the shopping cart as a whole and to identify when the shopping cart data changes |
| wp_woocommerce_session_ | When the browsing session ends | Uniquely identifies each customer so that it can identify shopping cart data from previous sessions. |
| PHPSESSID | When the browsing session ends | Used in connection with Members section to allows Members to view password protected content and pages during that current session. |
| wordpress | 15 days after the browsing session | Used to identify logged-n users. |
We also use log files when you visit our Site. Log files track IP addresses, browser type, Internet Service Provider (ISP) identity, referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information in our legitimate interest in administering the Site, preventing fraud, tracking website navigation in the aggregate, and gathering broad demographic information for aggregate use.
Google Analytics
We use Google Analytics in connection with our Site to gather data such as age, gender and interests to provide advertising targeted to suit your interests and preferences.
Google Analytics collects anonymous information that is not used to identify a particular user. This information helps us better understand how visitors use our Sites, detect and defend against fraud and other security risks, and present advertisements, products, and/or services of interest to you.
To learn more about how Google Analytics collects and processes data, please visit “How Google uses data when you use our partners’ Sites or apps”, located at www.google.com/policies/privacy/partners/. To learn about how to opt-out of Google Analytics, please visit http://tools.Google.com/dlpage/gaoptout/.
Use of Your Personal Information
We use your Personal Information to further legitimate business interests – to transact business with you and serve you as a customer and to administer our Site and prevent fraud. As described above, we use your Personal Information to answer your inquiries, provide you with information on our products and services, enable you to participate in online transactions, personalize content so that it applies to you and your interests, compile, analyze, and do research on our user’s demographics and behavior, and detect, investigate, and prevent activities that may violate our policies or be illegal. We may also use your Personal Information to communicate with you about products and services we believe you might find of interest and to administer promotions, surveys, contests and sweepstakes in which you might participate.
We also use the information automatically collected about you during your use of the Site as described above, to improve the effectiveness of our websites, operations, mobile experience, or marketing efforts or as described elsewhere in this policy, to prevent fraud and theft, and otherwise to protect our Sites’ visitors and our business.
Our employees and agents may view your Personal Information to perform their jobs and service your needs. We authorize access to your Personal Information to them on a need-to-know basis to provide you with our products or services to you, or for one of the other reasons listed in this section.
Sharing Your Personal Information
As a general rule, we do not sell and we will not disclose any of your Personal Information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the legitimate business-related circumstances described in this Policy. For instance, we may share your Personal Information in the following circumstances:
We may disclose your Personal Information if we determine that disclosure is reasonably necessary to enforce our Terms of Use (https://www.pinionglobal.com/terms-of-use), this Privacy Policy or to otherwise protect our operations, clients or users.
We may release your Personal Information to others (including law enforcement) if we believe such release is reasonably necessary to comply with the law or legal process; enforce or apply the terms of applicable terms of use; detect, prevent, or otherwise address fraud, security or technical issues; or otherwise protect the rights, property or safety of others.
We may sell, transfer and/or disclose your Personal Information as part of a business divestiture, sale, merger, or acquisition of all or a part of our business. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.
In addition, we may share aggregate, non-individual information, incapable of identifying a particular person, with third parties for lawful purposes.
California Privacy Rights
If you are a California resident, you have certain rights with respect to your personal information. Specifically, the California Consumer Privacy Act provides you with the following rights:
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1. the right to know, by way of our Privacy Policies and any specific inquiries you direct to us, where personal information we have about you comes from, what we use that information for, whether it is being disclosed or sole, and to whom it is being disclosed or sold;
2. the right to “opt-out” of Pinion’s sale of your Personal Information to any third parties;
3. the right to request Pinion to limit or stop sharing of your Personal Information to third parties;
4. the right, with some exceptions, to have your Personal Information deleted from Pinion’s possession or control;
5. the right to correct inaccuracies in your Personal Information; and
6. the right to not be retaliated against for exercising your privacy rights.
If you are a California resident, you may have the right to request and receive certain information about a company's disclosure of your personal information to third parties for their own direct marketing use, and your choices with respect to such disclosures. Our Site does not authorize the collection of personal information by third parties except as provided in this Privacy Policy. And, in the past twelve (12) months, KCoe has not sold any personal information to any third parties.
If you are a California resident under the age of 18, and a registered user of any Site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to kcoe@kcoe.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
If you have any questions or concerns about your California privacy rights, our Privacy Policy, or our use of your personal information, you may direct your inquiries to:
K·Coe Isom, LLP
Attention: California Data Privacy
3030 Cortland Cir
Salina, Kansas 67401
Email: kcoe@kcoe.com
1-800-461-4702
For all California residents, any such inquiries shall be responded to within forty-five (45) days and at no cost to you.
Links to Other Websites
You may be able to post content to Social Networking Sites (such as Facebook, Linked-In, Twitter, and Google+) on which we maintain a presence. If you choose to do this, we will provide information to the Social Networking Sites, and receive information from them, in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review applicable terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products or services of such Social Network Sites.
While you are using the Site, you may be linked or directed to other third-party sites outside of our Site that are beyond our control. Each of these third-party sites may have a privacy policy or terms of use different from ours. Please carefully review the applicable policies of these sites. We are not responsible for any actions or policies of such third parties.
Data Movement
We may maintain your Personal Information on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
We process data, including Personal Information, in the United States. We do not transfer your Personal Information to another organization or a country absent the existence of adequate security and privacy controls. We transfer Personal Information to the United States only with your consent or to perform a contract with you, and consistent with the practices described in this Privacy Notice. We do not collect or store sensitive information about you.
Security Measures
We maintain a variety of industry-standard security measures, including physical, electronic and procedural safeguards. For instance, the Site, and all information associated with the Site, are hosted on Amazon’s AWS cloud behind Amazon’s extensive and secure firewall and is only accessible to those having a need to do so. The host of the Site also utilizes a web application firewall (WAF) that protects the Site from brute-force attacks, spam comments, bot registrations, SQL injection hacking, DDoS, and other attacks. No system can be completely secure, so we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure.
Your Access to Your Data and Consent to Our Use of your Personal Information
If you believe that the Personal Information that we have collected about you is incomplete, inaccurate, or not up to date, or if you would like to review and/or request changes or deletion of that information, you can contact Tom Delaney, Privacy Officer.
If you do not consent or want to withdraw your consent for us to collect, use, or disclose your Personal Information as described in this Policy, or if you wish to restrict K·Coe‘s ability to process your Personal Information because of perceived inaccuracies, please contact Tom Delaney, Privacy Officer . In your request, please identify the Personal Information at issue and the collection, use, or disclosure you wish to stop.
If you are a resident of the European Union or California, you may have the right to request that K·Coe delete any personal information we may possess or control about you. Subject to any exceptions and pursuant to such laws, where applicable, K·Coe will comply with any such request and shall provide notice of such deletion, or of any restrictions as noted in the previous paragraph, to recipients of your Personal Information.
Denying or withdrawing consent may not allow us to provide you with some or all of the products, services, or information you request.
You may opt-out of receiving marketing-related emails by clicking the "unsubscribe" link at the bottom of any email you receive from us. If you are having difficulty unsubscribing from our marketing communications, please contact us at marketing@kcoe.com or 1-800-461-4702.
If you opt-out from receiving marketing emails or text messages, we may still need to send you communications about your, orders, member service inquiries, and other matters.
If you agreed to receive future marketing communications directly from a third party through our Site, you will need to contact that party to opt-out of such communications. This process may be outlined on that party's privacy policy.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. Changes and clarifications will take effect immediately upon their posting on the Site and we will change the “Last Modified” date below.
Questions and Contact Information
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, you may contact our Data Privacy Officer at:
Tom Delaney
3030 Cortland Circle
Salina, KS 67401
kcoe@kcoe.com
1-800-461-4702
Last Modified: March 7, 2019
