Privacy Policy

Updated August 1, 2018



At The Chotin Group Corporation (“Chotin,” “we,” “us”) we recognize the sensitivity of the personal information that you share with us, and we are firmly committed to protecting your privacy. This Privacy Policy describes the types of information we may collect from you when you visit any Chotin owned websites and domains (collectively, the “Sites”), and use our services (“Services”).

Privacy Principles

We follow the following principles in order to protect your privacy: • We do not collect any more personal information about you than is necessary; • We only use your personal information for the purposes we specify in this Privacy Policy, unless you agree otherwise; • We do not keep your personal information if it is no longer needed; and • Other than as we specify in this Privacy Policy, we do not share your personal information with third parties.

How We Collect and Use Personal Information

We collect personal information about you in two ways: (1) when you share personal information directly with us, and (2) automatically when you use the Site or our Services.

We may collect information about your computer, including but not limited to your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns, and helps us to improve our services and the Site.

Personal Information that You Provide

You may choose to share certain information with us, for example, if you communicate with us through our “Contact Us” webpage or if you sign up to use our Services. The basic personal information we collect includes: • Name, • Email address

If you are applying for a position or an application, we may ask for some additional personal information, such as your job experience and history, demographic information, and financial information.

We collect and process this information pursuant to your consent as well as our legitimate business purposes.

Information We Collect Automatically

In addition to the personal information you may provide to us as described above, we automatically collect certain device and statistical information using Google Analytics to make the Site work better for you. This information helps us evaluate how individuals may use the Site, including data analysis, and identifying usage trends.

The technologies we use to gather this non-personal information include:

IP Addresses: IP addresses define the Internet location of computers and help us better understand the geographic distribution of our members and manage the performance of the Site. We use your IP address to help diagnose problems with our server, and to administer the Site.

Web logs: To learn about how people use the Site, we examine Web logs, which show the paths people take through our site and how long they spend in certain areas. We also use Web logs to detect the type of Web browser you are using so that we can optimize the performance of our Web site and understand the mix of browsers used by our members.

Cookies: Cookies are tiny files that are placed onto the hard drive of your computer when you visit the Site. They let us immediately recognize you when you return to the site. This enables us, among other things, to personalize your experience with our site. You can learn more about cookies by visiting www.allaboutcookies.com, and you can modify your cookie setting by following the instructions provided by your browser. These instructions are usually found in the “Tools,” “Help” or “Edit” tabs. If you set your browser to disable cookies you may not be able to fully access and use our Sites. You can learn more about the choices provided by advertisers for individuals to decide how their information is collected and used by visiting the Digital Advertising Alliance (www.aboutads.info), the Network Advertising Initiative (www.networkadvertising.org/managing/opt_out.asp) or the European Digital Advertising Alliance (www.youronlinechoices.eu).

Security

We have implemented measures intended to protect your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Please note that the electronic transmission of information is not completely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that such measures will always be sufficient or effective. Any transmission of personal information is at your own risk.

Retention

We will retain your information for as long as needed to fulfill your requests, provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.

Disclosure of Your Personal Information

We may disclose aggregated, or other non-personal information about our users without restriction. We may disclose personal information about you in the following ways and/or to the following third parties:

Affiliates. To our parents, affiliates, and partners, for their use in a manner consistent with the purpose described in this Privacy Policy.

Agents and Service Providers. To contractors, service providers, and other third parties we use to support our business, provide the Services, and who complete transactions or perform services on our behalf or for your benefit. These third parties are only given the personal information they need to perform the services we ask them to, and can only use it for those purposes.

Legal Process. As required by law, such as to comply with a subpoena or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Certain Business Transfers. As part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. It may also be disclosed in the event of insolvency, bankruptcy, or receivership. We will use reasonable efforts to direct any such transferee to use your personal information in a manner that is consistent with our Privacy Policy.

Consent. In additional ways upon your consent.

Your Rights

You can contact us at any time to make the following requests:

Request a Copy of your Personal Information. You have the right to request a copy of any personal information that we hold about you. If you would like a copy of your personal information, please contact us using the contact information below. We may request proof of your identity before sharing such information. If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information by contacting us using the contact information below.

Cease Processing or Delete Personal Information. You may ask us to stop processing the personally identifiable data we hold about you in certain circumstances. It may not be possible for us to cease processing all of the information we hold about you where we are fulfilling a transaction or have a legal basis to retain the information, however please contact us to discuss how we can assist you with your request.

Withdraw Consent. When we process your information on the basis that you have consented to such processing, you have the right to withdraw your consent, or ask us to stop or restrict processing the personal information we have about you, at any time by contacting us using the contact information below.

Unsubscribe. If you receive marketing emails from us, you can unsubscribe to our emails by clicking "unsubscribe" within each email. You may not opt-out of service-related communications, which are not promotional in nature.

Where We Store Your Personal Information

Chotin is located, and the Site is hosted, in the United States of America. In order for us to provide our services to you, it will be necessary for us to process and store personal information you provide to us in the United States of America, which may have different data protection laws than those in the country in which you reside.

Children Under the Age of 13

The Services are not directed to, and Chotin does not knowingly collect or solicit personal information from, children under the age of 13. If we learn we have collected or received personal information from a child under the age of 13, we will delete that information. Please contact us if you believe we might have any information from or about a child under the age of 13.

Your California Privacy Rights California Civil Code Section § 1798.83 permits users of our Site and/or Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Please contact us to make such a request.

Changes and Updates

We have the discretion to update this Privacy Policy at any time. When we do, we will revise the updated date at the top of this page. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on the Site prior to the change becoming effective. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.

Contacting Us If you have any questions about this Privacy Policy or the practices of or your dealings with this Site, you can contact us at:

The Chotin Group Corporation.
Attn: Nicole Brown
5675 DTC Boulevard, Suite 200
Greenwood Village, Colorado 80111 USA
(303) 741-0100

Or:

nbrown@chotin.com