Privacy Policy
We respect the privacy of every person who visits www.carlinwestagency.com (the “Website” or “Site”) and who uses the services that we make available from the Site (our “Services”) and we are committed to ensuring a safe online experience.
1. Purpose of this Policy
This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.
This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.
This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it.
Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.
2.Who are we and what do we do?
The Site and our Services are operated by Carlin West Agency, LLC, (“Carlin West Agency,” “CWA,” “we”, “us” or “our”).
CWA is the data controller responsible for your personal information
CWA is a limited liability company with registered in the state of New York State and whose main address is 135 E 57th St Suite 16-108, New York, NY 10022.
3. How to contact us?
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:
sending an e-mail to info@fredabird.com;
writing to us at:
Carlin West Agency
135 E 57th St
Suite 16-108
New York, NY 10022
4. What personal information do we collect and how do we use it?
Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties, including our other clients and users of the Site; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law.
In particular, we may use your personal information for the following purposes:
Fulfillment of requests.
We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services. We may use the contact details you have provided to us so that we can fulfill requests for information and other matters related to our products and services. This includes your attendance at events hosted by us, questions or requests regarding our products and services.
Who do we share your personal information with for this purpose?
Except as otherwise set forth herein, we will not share your personal information with third parties.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.
Client service inquiries.
Our Site uses various user interfaces to allow you to request information about our products and services: these include printed and electronic inquiry forms and a telephone inquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your inquiry. This information is used in order to enable us to respond to your requests.
Who do we share your personal information with for this purpose?
Except as otherwise set forth herein, we do not share your personal information for this purpose.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.
Who do we share your personal information with for these purposes?
Except as otherwise set forth herein, we do not share your personal information for this purpose.
What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
Customer insight and analysis.
We may analyze your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services.
Where you have given your consent (where lawfully required), we may use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile. This includes the following:
an IP address to monitor Sites traffic and volume;
a session ID to track usage statistics on our Sites;
information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.
Who do we share your personal information with for these purposes?
We may share your personal information with third party service providers to assist us with customer insight analytics.
What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.
We will only use your location data for customer insight purposes where we have your consent to do so.
Email marketing.
We may use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.
Who do we share your personal information with for these purposes?
We may share your personal information with third party email marketing providers who assist us in delivering our email marketing campaigns to you.
What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.
Online personalized advertising.
We may use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized online advertising.
Who do we share your personal information with for these purposes?
We share your personal information with third party service providers who assist us with our online personalized advertising campaigns.
What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:
to comply with our legal obligations;
to enforce our legal rights;
protect rights of third parties; and
in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Where we share your sensitive personal information, we shall obtain your consent to do so.
Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.
5. How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
at the time we collect your personal information following the instructions provided; or
by informing us by e-mail or post using the contact details set out in this Privacy Policy.
6. How long do we keep your personal information for?
We keep your personal information for a period of 6 years from the date of our last interaction with you.
If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it sooner.
7. Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
unauthorized access;
improper use or disclosure;
unauthorized modification; and
unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
8. How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you:
Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability.
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
processing your personal information for direct marketing
Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
9. California Privacy Rights
If you are a California consumer and would like information about our online and offline privacy practices and your privacy rights, please click here.
10. Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time.
To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.
Privacy Policy Effective Date: February 12, 2020