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This Privacy Policy has been adopted
by COLT INTERNATIONAL (“Colt”) in
compliance with Section 35.581 of the Texas Business & Commerce
Code. This Privacy Policy has also been structured
to conform to applicable industry standards and practices
existing at the time of its posting, including those
promoted by the Online Privacy Alliance at www.privacyalliance.org,
trust-e at www.etrust.com or www.truste.com, among
others. This Privacy Policy describes:
(a) How
Personal Identifying Information is collected;
(b) How
and when Personal Identifying Information is used;
(c) How
Personal Identifying Information is protected; and
(d) How
Personal Identifying Information is disposed.
Except as described in this Privacy Policy, Colt does
not intentionally disclose Personal Identifying Information
to any third party. It is Colt’s policy,
as set forth hereunder, to protect Personal Identifying
Information. However, in no event does Colt warrant
or guarantee the complete secrecy of such information.
1. Definitions. For purposes of this Privacy Policy,
the following terms shall have the meanings assigned
to them hereunder:
(a) "Business record" means letters,
words, sounds, or numbers, or the equivalent of
letters, words, sounds, or numbers, recorded in
the operation of a business by: (i) handwriting;
(ii) typewriting; (iii) printing; (iv) photostat;
(v) photograph; (vi) magnetic impulse; (vii) mechanical
or electronic recording; (viii) digitized optical
image; or (ix) another form of data compilation.
(b) "Personal Identifying Information" means
an individual's first name or initial and last
name in combination with any one or more of the
following items: (i) date of birth; (ii) social
security number or other government-issued identification
number; (iii) mother's maiden name; (iv) unique
biometric data, including the individual's fingerprint,
voice print, and retina or iris image; (v) unique
electronic identification number, address, or routing
code; (vi) telecommunication access device, including
debit and credit card information; or (vii) financial
institution account number or any other financial
information.
2. How Personal Identifying Information is collected.
(a) Colt’s Credit Application. As part of Colt’s
credit application process "Personal Identifying
information" may be voluntarily obtained
from each customer of Colt or, if applicable, an individual
guarantor of the customer’s account. Colt may
also obtain information about a customer’s
or a guarantor’s creditworthiness and credit
history from consumer reporting agencies; such
information may consist of Personal Identifying
information. Colt may also collect background information
from third-parties to verify representations made
to Colt; such responsive information may consist
of Personal Identifying information.
(b) Colt Website. If you are visiting the Colt
website (http://www.coltinternational.com), Colt
collects the following information: the full Uniform
Resource Locator ("URL")
of the Web page from which you came to the website; your Internet Protocol ("IP")
address, which may include a domain name; the date
and time for each page you view; the name of and
information about any advertisement that brought
you to the Colt website; searches you perform,
links you click on; and computer and connection
information such as browser type and version, operating
system, and platform. Colt also transmits cookies
to your computer so we can track the pages of our
website that you view and the order in which you
view them. Any other information that you might
submit to the Colt website, including Personal
Identifying Information, may be maintained by Colt.
(c) Communications with Colt. If you communicate
with Colt, we may store copies of such communiqués (including e-mail or similar communications). This
can result in the collection of Personal Identifying Information you may have
disclosed in your communiqués.
3. How and when Personal Identifying Information is
used.
(a) Personal Identifying Information voluntarily
provided by or on behalf of Colt’s customers
is used by Colt as part of our credit application
process. This would include both the establishment
of credit with Colt, and, if necessary, for use
by Colt and its legal representatives in enforcing
and/or collecting delinquent accounts.
(b) Personal Identifying Information may also be used
by Colt as part of its providing goods and/or services
to its customers and in respond to billing and/or
other such questions related to such goods and services.
(c) "Cookies" are files stored on your
computer's hard drive by your browser. Colt may
use cookies for such functions as verifying that
you are an Colt user, counting and tracking your
Colt website visits, setting the appearance of
the toolbar, helping the toolbar remember which
module and tab you were last on and which search
feature you used last, remembering the default
search engine that you used in our Web search feature,
determining the length of time you spent on a Web
page, and keeping the nickname you used when you
wrote your last Web review. We further use cookies
to determine the number of visitors that came to
the Colt website through a particular advertisement.
Your Colt cookie number is also used to create
usage and shopping paths and to correlate those
with any demographic information you provide, but
we do not use your cookies, usage paths, shopping
paths, or product purchasing information to attempt
to determine your identity. Your cookie also may
contain information about the last several websites
that you visited.
(d) Colt may use IP addresses to diagnose problems
with our servers and to administer our website. Your
IP address also is used by Colt to gather broad demographic
information, such as your general geographic location
and Internet Service Provider. IP addresses are further
used to help determine the number of Colt users. This
demographic information may also be used by Colt to
analyze aggregate Web usage behavior.
(e) If you gave Colt your e-mail address, we may use
it to send you Colt newsletters, product updates,
service-related information, and other offers and
information from Colt. Colt also may contact you by
e-mail to respond to your submissions and customer
service inquiries.
(f) Colt may disclose any information we possess in
response to subpoenas, court orders, or legal requirements,
and such information might be used by the receiving
party to determine your identity, your Web usage and
online shopping behavior, or other things about you.
(g) Colt may employ other companies and individuals
to perform functions on our behalf, such as technical
support services. To perform those functions, it may
be necessary for them to obtain access to Colt databases
and servers, which may contain Personal Identifying
Information.
(h) Colt may also employ attorneys, financial advisors,
accountants and/or auditors who, in their performance
of services on behalf of Colt might have access to
Personal Identifying Information.
4. How Personal Identifying Information is protected.
(a) All Personal Identifying Information received
in the normal course of business is treated as
Colt’s
other Proprietary Information.
(b) All employees of Colt are required to sign
Non-Disclosure Agreements that prevent their disclosure
of such information. Effective with Non-Disclosure
Agreements executed on or after October 1, 2005,
Personal Identifying Information is specifically
included within the definition of Colt’s
Proprietary Information.
(c) Colt attempts to physically secure “hard copies” of
our Business Records containing Personal Identifying
Information.
(d) Colt uses commercially reasonable computer security
safeguards to protect our databases and servers against
risks of loss, unauthorized access, destruction, misuse,
modification, or inadvertent or improper disclosure
of data. These risks, however, cannot be completely
eliminated and Colt therefore cannot guarantee complete
security.
(e) If you send Colt an email, you should know that
email is not necessarily secure against interception.
So, if your communication includes Personal Identifying
Information and you prefer not to contact us by postal
mail or telephone rather than email.
5.
How Personal Identifying Information is Disposed. When Colt disposes of a Business Record that contains
Personal Identifying Information, Colt will modify
the Personal Identifying Information by shredding,
erasing, or other means, to make it unreadable or
undecipherable. Colt may, but shall not be required
to contract with a person engaged in the business
of disposing of records for the modification of Personal
Identifying Information.
If you have any questions regarding Colt’s Privacy Policy, please contact
Colt at 281-280-2100.
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