Last Update: October 2023
I. The Information Cabot May Collect and How It Will Be Used
Cabot collects personal data (i.e., information that can be used to identify you) through your use of the Site, including from comments and questions from visitors to the Site, and when you otherwise interact with us. Cabot will only use such personal data where it is necessary to do so because it is relevant to Cabot's dealings with a visitor, where it has his/her consent, or as otherwise permitted by applicable laws. In the course of regular business, we may collect and process the following categories and examples of personal data about you:
- Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers;
- Personal information categories under California law and other applicable data protection laws and regulations in the jurisdiction where you are located, including name, signature, address, and telephone number (some personal information included in this category may overlap with other categories);
- Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- Professional or employment-related information;
- Geolocation data, such as geographic location information about a particular individual or device;
- Internet or other similar network activity, such as browsing history, search history, and information regarding your interaction with and use of our website; and
- Inferences drawn from any of the information described above to create a profile about an individual reflecting the individual’s preferences.
Cabot does not require personal data from a visitor to obtain access to the general public areas of the Site, but such data may be required to request or download product information or take advantage of other features on the Site.
Cabot will use your personal data where it is necessary to do so for such purposes as verifying the identity of visitors to the Site, creating user credentials such as usernames and passwords, processing and responding to requests, improving its operations, maintaining details of its business contacts, facilitating business transactions and developing new business. We may also process your personal data to market products and services which we think may be of interest to you, or to communicate with you for other purposes.
Cabot also collects non-personal data and uses it in aggregate form to track data such as, but not limited to, the total number of visits to the Site, the number of visitors to each page of the Site, and the domain names of our visitors' Internet Service Providers. We use this information to understand how our visitors use the Site so that we may improve the Site and the services we offer. The Site is not directed at collecting personal data from minors, and we do not knowingly collect such data from minors.
Cookies are small pieces of information, stored in simple text files, placed on your computer or device by a website. Cookies are used by the website on subsequent visits. The information stored in a cookie may relate to your browsing habits on the web page, or a unique identification number so that the website can “remember” you on a return visit.
The following are categories of cookies used by Cabot:
- Session cookies. These are temporary and are deleted as soon as you close your Internet browser.
- Persistent cookies. These are stored on your computer or device until they expire or you remove them. They store personal preferences such as your language preferences on multi-lingual sites to make subsequent visits easier.
- Third-party cookies. We work with third parties who, on our behalf, research the use of our website and activities on it. In doing so they may place a cookie on your computer or device. However, it would not contain any personal data that others could read and understand.
If you do not wish to receive cookies from the Site, you can set your browser to warn you before accepting cookies and refuse the cookie when alerted by the browser to its presence. Cookies can also be refused by turning them off in the browser. Please refer to your web browser's instructions or help screen to learn more about these functions.
III. How Cabot Protects Your Personal Data
Cabot is committed to protecting the security of your personal data. Cabot takes commercially reasonable steps designed to protect your personal data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and other unlawful forms of processing. Some areas of the Site may require pre-qualification or registration for access and, if access is granted, may require a username, password or other technique to control access. Registered visitors should carefully safeguard their username and password and only make it available to authorized agents. If registered visitors become aware of any unauthorized use of a password, they should notify Cabot.
Despite the security measures that we have put in place to protect your personal data, no such measures can guarantee security or protect against unauthorized activity.
We will keep your data for as long as you maintain a business relationship with us and afterwards in accordance with our legal and regulatory obligations. When deciding how long to retain your personal data, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means. We may also retain your personal data to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
IV. Sharing Information With Third Parties
Cabot will exercise appropriate due diligence in the selection of its third-party service providers and will require via appropriate contractual measures that such third-party service providers (i) maintain adequate technical and organizational security measures in order to protect the confidentiality of the data; and (ii) process data only as instructed by the relevant Cabot affiliates.
A. Business Partners, Contractors and Service Providers
Cabot contracts with select business partners, contractors and service providers to market and distribute products in certain areas or to provide Cabot with support services in connection with the Site. These business partners, contractors and service providers may, from time to time and in accordance with applicable law, have access to your personal data to enable them to provide services to Cabot or directly to Cabot's customers. For example, Cabot may share your personal data with a business partner in order to respond to product inquiries that you make on the Site.
B. Third Party Direct Marketing
We will not sell or otherwise transfer any personal data that you provide to us to any third parties for their own direct marketing use unless we provide clear and prior notice to you or obtain your explicit consent in accordance with applicable law.
C. Legal and Business Transfers
- to monitor and analyze trends, usage and activities in connection with our services and Site, and for marketing purposes to the extent permissible under with applicable law;
- to detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Cabot and others;
- when we have reason to believe, in good faith, that disclosing your personal data is necessary to identify, contact or bring legal action against someone who may be causing injury to you, or otherwise injuring or interfering with Cabot's rights, property, or operations, other users of the Site, or anyone else who could be harmed by such activities;
- to comply with any legal, regulatory, or contractual obligation;
- when we believe, in good faith, that disclosure is required by law;
- in response to a demand by law enforcement authorities in connection with a criminal investigation;
- in response to a request by civil or administrative authorities in connection with a pending civil case or administrative investigation;
- in the event of a merger, acquisition, sale of assets, joint venture, or any other transaction that results in a change in control or ownership of Cabot, in whole or in part; or
- in the event of a corporate reorganization, bankruptcy, insolvency proceeding, or similar circumstance, if permitted by and done in accordance with applicable law.
Because the Internet and our operations are global, your personal data may be transferred to, processed in, and held in countries (including the United States) other than the one in which you reside. The European Union and United Kingdom do not consider the United States and other countries to provide equivalent privacy protections. When we transfer personal data internationally, and to the extent required by applicable data protection laws, we rely on appropriate or suitable safeguards, including: where the relevant country or recipient has been deemed to provide an adequate level of protection for your personal data by relevant authorities; using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards; obtaining your consent to transfer personal data after informing you about the possible risks of such a transfer; and transferring the personal data is necessary for the performance of (or to enter into) a contract between you and Cabot, or because the transfer is necessary for the performance of a contract between Cabot and a third party, and the contract was entered into in your interest.
V. Your Rights
Depending on your jurisdiction, you may have certain data subject rights. These rights vary and may be subject to certain limitations and exemptions, but they may include the right to:
- know what personal data we collect, including (a) the right to request information regarding the categories of personal data that we collect along with other information such as the categories of sources from which the data is collected and third parties with whom it is shared and (b) the right to request a copy of the specific pieces of personal data that we collect (sometimes referred to as the right to access personal information);
- correct or delete personal data;
- object to or restrict the processing of personal data, including to limit the use or disclosure of sensitive personal data under certain circumstances;
- obtain a copy of your personal data in a portable format; and
- other rights you are entitled to under the applicable laws and regulations in the jurisdictions where you are located.
Individuals may also have the right to not be discriminated against for exercising applicable data subject rights, and to lodge a complaint about the processing of personal data with a data protection authority.
The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. To exercise your data subject rights, please contact us firstname.lastname@example.org or at the mailing address included below in the Contact Information section. If you make a request related to personal data about you, we will need to verify your identity. For example, if your request is made to Cabot in writing, it must be signed and accompanied by a photocopy of a valid identity card or other valid identification document showing the signature of the holder. Such requests must also specify the address to which a response may be sent. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.
Cabot shall respond to all such requests as soon as reasonably possible and at the latest within the relevant deadlines set forth by applicable law, which may vary.
VI. California Shine the Light Disclosure
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties without your consent for their direct marketing.
VII. Links to Other Websites
Where the implementation of this policy requires further action to comply with local laws or company obligations in a given jurisdiction, such as local consultation, registrations, translation or other legal formalities, such action will be taken before the policy is implemented in the jurisdiction. Nothing in this policy is intended to nor shall modify or amend in any way the provisions of an employment agreement between Cabot and any of its employees. If you are a Cabot employee, please refer to the applicable Employee Fair Processing Notice for your jurisdiction. For additional information regarding the use of customer information, please refer to the applicable Customer Fair Processing Notice for your jurisdiction.
IX. Contact Information
If you have any questions or concerns concerning your personal data, please send a thorough description to email@example.com or the address below and we will respond within a reasonable period of time and at the latest within the relevant deadlines set forth by applicable law, which may vary.
Global Data Protection
Two Seaport Lane, Suite 1400
Boston, MA 02210-2019
Telephone: +1 (617) 345-0100